Experience with EA for PTP permission to drain to culvert

[Alan Ambrose]

For anyone else in this situation, I thought I'd document my experience with the EA applying on form EPB B6.5 for an application to drain a STP to the culvert at the back of my plot. This should be fairly straight-forward as my 5 neighbours all drain their PTPs to the same culvert, duh, and the nearest villages with actual sewers are a couple of miles away...

 

+ I sent in my 24-page EPB Part B6.5 form and block plan back (and payment) in May and got a receipt for the payment about a week later. I got a call from an EA drainge person last Friday ... that's 5 months. I have asked for status updates by email a couple of times and those were ignored. I called about 6 weeks ago and they told me (a) we can't find your application, send it again and (b) it'll go on the top of the queue.

+ FWIW (a) I think there's something dodgy with their email receipt mailbox and (b) they don't seem to reconcile the applications with the payments.

+ About a week ago, I sent in another status request by email and was told that my application would, in fact, go at the back of the queue. I asked them to start a formal compaint.

+ An EA guy called me late last Friday with a few extra questions - he wanted grid references for everything and a description of the flow all the way to the first named watercourse - which is a river 3.6km away. Gave me 5 days to reply. Yeah right. He said it might take another 4 weeks to approve the application assuming everything was good. So, that'll be end-November, 6 months.

 

BTW I found this reference https://gridreferencefinder.com/  - which is good for converting one style of grid ref to another and also for getting grid refs from maps.

[IanR]

28 minutes ago, Alan Ambrose said:

This should be fairly straight-forward as my 5 neighbours all drain their PTPs to the same culvert, duh, and the nearest villages with actual sewers are a couple of miles away...

 

Does the Culvert have have water in it for most of the year? Do your neighbours have permits or are they using the General Binding Rules?

 

Can you not discharge under the general binding rules or is there a neighbour within 50m of your discharge point already doing so?

[Alan Ambrose]

>>> Can you not discharge under the general binding rules

 

No, otherwise I wouldn't have put the application in.

 

It's actually a bit hard for the uninitiated to navigate when and when to not use the rules. As I looked at them back in May, I don't remember which bits didn't fit when I sent the application in, but I'm sure the EA would have pointed it out if they thought I didn't need to apply. As far as I can see, the general binding rules came in in January 2015. My neighbours have houses ranging from hundreds of years old to ones built in the 1940 to 1960s - so there will have been little if any paperwork for them to do then. They kind of get 'grandfathered in' - which is usual but a whole topic in itself.

 

On reflection, the system seems a bit bonkers - someone's designed something to 'cover all bases', but it's hugely inefficient at processing simple applications, both for the applicants and the EA.

 

[IanR]

2 minutes ago, Alan Ambrose said:

but I'm sure the EA would have pointed it out if they thought I didn't need to apply.

 

Nope, they'll assume you've gone through the rules and worked out you can't discharge under them.

 

4 minutes ago, Alan Ambrose said:

As far as I can see, the general binding rules came in in January 2015. My neighbours have houses ranging from hundreds of years old to ones built in the 1940 to 1960s - so there will have been little if any paperwork for them to do then.

 

Yes, but... pre-2015 still have to follow the rules, which likely means having a plan to upgrade within 12 months. If they don't have a permit, then they are under the rules, if they're not discharging within the pre-2015 rules they're at risk of a prosecution, but in the context of your connection, they are discharging "within the rules".

If your discharge would be wihtin 50m of one of your neighbours (that doesn't have a permit) then you can't discharge within the rules. (but you could have done pre-2013) If you can position your discharge 50m away from the closest neighbour's discharge, then you can discharge under the rules.

[Alan Ambrose]

@IanR

 

>>> If they don't have a permit, then they are under the rules, if they're not discharging within the pre-2015 rules they're at risk of a prosecution, but in the context of your connection, they are discharging "within the rules".

 

I don't quite understand that - assuming they have OK treatment plants, do they have to do something or are they good?

 

In further news, I had a call (23.4 weeks in) from an EA guy asking for a few more scraps of info - including the entire 3-4km route to a 'named river'. A day after I provided that info, the EA guy said that he had what he needed and a decision should arrive in about 4 weeks - which will be ~28 weeks total. I trust that the decision will be 'yes' as I don't have any other options

[IanR]

20 minutes ago, Alan Ambrose said:

>>> If they don't have a permit, then they are under the rules, if they're not discharging within the pre-2015 rules they're at risk of a prosecution, but in the context of your connection, they are discharging "within the rules".

 

I don't quite understand that - assuming they have OK treatment plants, do they have to do something or are they good?

 

pre-2015 discharges have to abide by the "Rules that apply to all discharges" section of the General Binding Rules. When you say "OK treatment plants", if you mean a (BS EN 12566) small sewage treatment plant or a package treatment plant then they are meeting the requirements of the rules, but if they are still on a septic tank as most "1940 to 1960s" properties would have originally been, then they must upgrade or get a permit (which they are unlikely to get without changes). Under the General Binding Rules the must have a plan to upgrade within 12 months.

Edited October 24 by IanR

[Alan Ambrose]

Wowee, got my EA permit today for my PTP drainage to an intermittent culvert. So, that's 6 months elapsed. The moral is to bother the EA on the phone until you're sure that the application is lodged in their system as it may well go astray. As ever, once you talk to an engineer type, everything starts to move from Kafkaesque to commonsensical.