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Crown Court
Magistrates

Individuals: Unauthorised or harmful deposit, treatment or disposal etc of waste/ Illegal discharges to air, land and water

Environmental Permitting (England and Wales) Regulations 2010, regulations 12 and 38(1), (2) and (3), Environmental Protection Act 1990, s.33, Environmental Permitting (England and Wales) Regulations 2016

Effective from 1 July 2014

Also relevant, with adjustments, to certain related offences.

Triable either way
Maximum: 5 years’ custody
Offence range: conditional discharge – 3 years’ custody

Use this guideline when the offender is an individual. If the offender is an organisation, please refer to the guideline for organisations.

Confiscation

Committal to the Crown Court for sentence is mandatory if confiscation (see step two) is to be considered: Proceeds of Crime Act 2002 section 70. In such cases magistrates should state whether they would otherwise have committed for sentence.

If a fine is imposed, the financial orders must be considered in this order: (1) compensation, (2) confiscation, and (3) fine (see Proceeds of Crime Act 2002 section 13)

User guide for this offence


Guideline users should be aware that the Equal Treatment Bench Book covers important aspects of fair treatment and disparity of outcomes for different groups in the criminal justice system. It provides guidance which sentencers are encouraged to take into account wherever applicable, to ensure that there is fairness for all involved in court proceedings.

Step 1 - Compensation

The court must consider making a compensation order requiring the offender to pay compensation for any personal injury, loss or damage resulting from the offence in such an amount as the court considers appropriate, having regard to the evidence and to the means of the offender.

Where the means of the offender are limited, priority should be given to the payment of compensation over payment of any other financial penalty.

Reasons should be given if a compensation order is not made.

(See sections 55 and 133 to 135 of the Sentencing Code)

Step 2 - Confiscation

Step 3 - Determining the offence category

The court should determine the offence category using only the culpability and harm factors in the tables below. The culpability and harm categories are on a sliding scale; there is inevitable overlap between the factors described in adjacent categories.

Culpability

Where there are factors present from more than one category of culpability, the court should weigh those factors in order to decide which category most resembles the offender’s case.

Deliberate

  • Where the offender intentionally breached, or flagrantly disregarded, the law

Reckless

  • Actual foresight of, or wilful blindness to, risk of offending but risk nevertheless taken

Negligent

  • Offence committed through act or omission which a person exercising reasonable care would not commit

Low or no culpability

  • Offence committed with little or no fault, for example by genuine accident despite the presence of proper preventive measures, or where such proper preventive measures were unforeseeably overcome by exceptional events

Harm

Dealing with a risk of harm involves consideration of both the likelihood of harm occurring and the extent of it if it does. Risk of harm is less serious than the same actual harm. Where the offence has caused risk of harm but no (or less) actual harm the normal approach is to move down to the next category of harm. This may not be appropriate if either the likelihood or extent of potential harm is particularly high.

Where there are factors present from more than one category of harm, the court should weigh those factors in order to decide which category most resembles the offender’s case.

Category 1

  • Polluting material of a dangerous nature, for example, hazardous chemicals or sharp objects
  • Major adverse effect or damage to air or water quality, amenity value, or property
  • Polluting material was noxious, widespread or pervasive with long-lasting effects on human health or quality of life, animal health, or flora
  • Major costs incurred through clean-up, site restoration or animal rehabilitation
  • Major interference with, prevention or undermining of other lawful activities or regulatory regime due to offence

Category 2

  • Significant adverse effect or damage to air or water quality, amenity value, or property
  • Significant adverse effect on human health or quality of life, animal health or flora
  • Significant costs incurred through clean-up, site restoration or animal rehabilitation
  • Significant interference with or undermining of other lawful activities or regulatory regime due to offence
  • Risk of category 1 harm

Category 3

  • Minor, localised adverse effect or damage to air or water quality, amenity value, or property
  • Minor adverse effect on human health or quality of life, animal health or flora
  • Low costs incurred through clean-up, site restoration or animal rehabilitation
  • Limited interference with or undermining of other lawful activities or regulatory regime due to offence
  • Risk of category 2 harm

 Category 4

  • Risk of category 3 harm

Step 4 - Starting point and category range

Having determined the category at step one, the court should use the corresponding starting point to reach a sentence within the category range in the table below. The starting point applies to all offenders irrespective of plea or previous convictions.

An adjustment from the starting point, upwards or downwards, may be necessary to reflect particular features of culpability and/or harm (for example, the presence of multiple factors within one category, the presence of factors from more than one category (where not already taken into account at step 1), or where a case falls close to a borderline between categories).

General principles to follow in setting a fine

The court should finalise the appropriate level of fine in accordance with section 125 of the Sentencing Code, which requires that the fine must reflect the seriousness of the offence and requires the court to take into account the financial circumstances of the offender.

The level of fine should reflect the extent to which the offender fell below the required standard. The fine should meet, in a fair and proportionate way, the objectives of punishment, deterrence and the removal of gain derived through the commission of the offence; it should not be cheaper to offend than to take the appropriate precautions.

Obtaining financial information

In setting a fine, the court may conclude that the offender is able to pay any fine imposed unless the offender has supplied any financial information to the contrary. It is for the offender to disclose to the court such data relevant to their financial position as will enable it to assess what they can reasonably afford to pay. If necessary, the court may compel the disclosure of an individual offender’s financial circumstances pursuant to section 35 of the Sentencing Code.

In the absence of such disclosure, or where the court is not satisfied that it has been given sufficient reliable information, the court will be entitled to draw reasonable inferences as to the offender’s means from evidence it has heard and from all the circumstances of the case.

Starting points and ranges

Where the range includes a potential sentence of a community order, the court should consider the community order threshold as follows:

  • a community order must not be imposed unless the offence is serious enough to warrant the making of such an order (section 204 of the Sentencing Code)
  • Where the community order threshold has been passed, a fine may still be the most appropriate disposal.
  • Where confiscation is not applied for, consider, if wishing to remove any economic benefit derived through the commission of the offence, combining a fine with a community order.

The tables below contain a non-exhaustive list of additional factual elements providing the context of the offence and factors relating to the offender. Identify whether any combination of these, or other relevant factors, should result in a further upward or downward adjustment. In some cases, having considered these factors, it may be appropriate to move outside the identified category range.

Factors increasing seriousness

Statutory aggravating factors

  • having regard to a) the nature of the offence to which the conviction relates and its relevance to the current offence; and b) the time that has elapsed since the conviction

Other aggravating factors include

  • History of non-compliance with warnings by regulator
  • Location of the offence, for example, near housing, schools, livestock or environmentally sensitive sites
  • Repeated incidents of offending or offending over an extended period of time, where not charged separately
  • Deliberate concealment of illegal nature of activity

Factors reducing seriousness or reflecting personal mitigation

  • Compensation paid voluntarily to remedy harm caused
  • Evidence of steps taken to remedy problem
  • One-off event not commercially motivated

Steps 5 and 6

Where the sentence is or includes a fine, the court should ‘step back’ and, using the factors set out in steps five and six, review whether the sentence as a whole meets, in a fair way, the objectives of punishment, deterrence and removal of gain derived through the commission of the offence. At steps five and six, the court may increase or reduce the proposed fine reached at step four, if necessary moving outside the range.

Step 5 - Ensure that the combination of financial orders (compensation, confiscation if appropriate, and fine) removes any economic benefit derived from the offending

The court should remove any economic benefit the offender has derived through the commission of the offence including:

  • avoided costs;
  • operating savings;
  • any gain made as a direct result of the offence.

Where the offender is fined, the amount of economic benefit derived from the offence should normally be added to the fine arrived at in step four. If a confiscation order is made, in considering economic benefit, the court should avoid double recovery.

Economic benefit will not always be an identifiable feature of a case. For example, in some water pollution cases there may be strict liability but very little obvious gain. However, even in these cases there may be some avoidance of cost, for example alarms not installed and maintained, inadequate bunding or security measures not installed. Any costs avoided will be considered as economic benefit.

Where it is not possible to calculate or estimate the economic benefit derived from the offence, the court may wish to draw on information from the enforcing authorities about the general costs of operating within the law.

Step 6 - Consider other factors that may warrant adjustment of the proposed fine

The court should consider any further factors that are relevant to ensuring that the proposed fine is proportionate having regard to the means of the offender and the seriousness of the offence.

The non-exhaustive list below contains additional factual elements the court should consider in deciding whether an increase or reduction to the proposed fine is required:

  • fine impairs offender’s ability to make restitution to victims;
  • impact of fine on offender’s ability to improve conditions to comply with the law;
  • impact of fine on employment of staff, service users, customers and local economy.

Step 7 - Consider any factors which indicate a reduction, such as assistance to the prosecution

The court should take into account section 74 of the Sentencing Code (reduction in sentence for assistance to prosecution) and any other rule of law by virtue of which an offender may receive a discounted sentence in consequence of assistance given (or offered) to the prosecutor or investigator.

Step 8 - Reduction for guilty pleas

The court should take account of any potential reduction for a guilty plea in accordance with section 73 of the Sentencing Code and the Reduction in Sentence for a Guilty Plea guideline.

Step 9 - Ancillary orders

In all cases, the court must consider whether to make ancillary orders. These may include:

Disqualification from driving

The Crown Court may order disqualification from driving where it is is satisfied that a motor vehicle was used (by the offender or by anyone else) for the purpose of committing, or facilitating the commission of, the offence (section 164 of the Sentencing Code).

The court may disqualify an offender from driving on conviction for any offence either in addition to any other sentence or instead of any other sentence (section 163 of the Sentencing Code).

The court should inform the offender of its intention to disqualify and hear representations.

In all cases, the court must consider whether to make ancillary orders. These may include:

Forfeiture of vehicle

The court may order the forfeiture of a vehicle used in or for the purposes of the commission of the offence in accordance with section 33C of the Environmental Protection Act 1990.

Deprivation of property

Where section 33C of the Environmental Protection Act 1990 does not apply, the court may order the offender to be deprived of property used to commit crime or intended for that purpose in accordance with section 153 of the Sentencing Code.

Remediation

Where an offender is convicted of an offence under regulation 38(1), (2) or (3) of the Environmental Permitting (England and Wales) Regulations 2016, a court may order the offender to take steps to remedy the cause of the offence within a specified period in accordance with regulation 44 of the Environmental Permitting (England and Wales) Regulations 2016.

Step 10 - Totality principle

If sentencing an offender for more than one offence, or where the offender is already serving a sentence, consider whether the total sentence is just and proportionate to the offending behaviour. See Totality guideline.

Step 11 - Reasons

Section 52 of the Sentencing Code imposes a duty to give reasons for, and explain the effect of, the sentence.

Step 12 - Consideration for time spent on bail (tagged curfew)

The court must consider whether to give credit for time spent on bail in accordance with section 240A of the Criminal Justice Act 2003 and section 325 of the Sentencing Code.


Other environmental offences

In sentencing other relevant and analogous environmental offences, the court should refer to the sentencing approach in steps one to three and five and six of the guideline, adjusting the starting points and ranges bearing in mind the statutory maxima for those offences.

Refer to Environmental offences (other) for an indicative list of such offences.

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