A forum for communication amongst Protected Wreck Licensees and Project Teams

© APWL 2015 - www.protectedwrecks.org.uk

Downloads

• MMO Consultation document (pdf)
• MMO Consultation letter (pdf)

•  APWL response (pdf)

•  NAS response (pdf)
•  JNAPC response (pdf)
• PADI response (pdf)

Responses to MMO Consultation on increasing licence fees - November 2013

In late 2013 the Marine Management Organisation issued a public consultation on proposals to increase fees for licences for smaller scale projects. Their justification was that they had to operate on a cost recovery basis and that these applications took far longer to process than was covered by the fee charged, so larger projects licence applications were effectively subsidising the smaller ones and that this was unfair.

Our reading of the consultation document was the exact opposite; that it clearly demonstrated that the MMO’s handlng of smaller licence applications is massively over bureaucratic and excessive for projects whose impact on the seabed is unquantifiably small (and so should not require a licence at all) and that rather than increase fees, they should seek to decrease the administrative burden of smaller scale applications, especially for work on protected wreck sites which is already licensed by the competent Government body (DCMS through English Heritage) and where the requirement for an additional (MMO) license was effectively a tax on the voluntary sector and totally contrary to the Government’s “big society” and “red tape challenge”.

The original consultation documents and our response (strongly worded and very detailed and long) and those from NAS, JNAPC and PADI are available from the box on the right.

As soon as we hear more we will let you know. Please do be assured that the likes of NAS and JNAPC are doing their utmost to get clarification and agreed exemptions for our work, but the MMO is simply ignoring all approaches and not engaging in dialogue with the community. We further understand that MMO will shortly withdraw all of its guidance for divers and has told the diving agencies to produce their own!!

What you can do

We urge you to forward our response to your local MP and ask them to press DEFRA (the MMO’s sponsoring Department) to take strong notice of our submission and to direct the MMO to do the same .

If you have had experience of MMO applications, good or bad, please do feedback to us so that we can collate information for everyone’s benefit.