Complexity Attribute Look-Up Table

The Complexity Attribute Look-up Table was a central component of the OPRA (Operational Risk Appraisal) scheme, which the Environment Agency officially withdrawn on 1 March 2019.

The below complexity attributes are used in the OPRA spreadsheet to attribute complexity to a waste operation. An operation with an "A" rated (low complexity) complexity attribute will cost less (application and subsistence fees) than a more complex operation. Example:

• Inert Waste Transfer Station - A - Application fee £2400

• General Waste Transfer Station  - C - Application Fee £8000

There are two "joke" complexity attributes in the below list. They are clearly labeled. Humour (or an attempt at it) is my only defense against this wall of hyper bureaucracy.

List of Complexity Attributes

A01 -Co-disposal landfill site -Open - EEE

A01 -Co-disposal landfill site -Closed  - B

A02 -Other landfill site taking hazardous waste -Open  - EE

A02 -Other landfill site taking hazardous waste -Closed

B2A03 -Borehole (Closed)

BA04 -Household, commercial and industrial waste landfill - Open -  DD

A04 -Household, commercial and industrial waste landfill -Closed - B

 A04 -Dredging sites B3A05 -Landfill taking non-biodegradable wastes -Open - C

A05 -Landfill taking non-biodegradable wastes -Closed

AL05 -Landfill Directive compliant inert landfill -Open

CL05 -landfill Directive compliant inert landfill -Closed   - A

A06 -Landfill taking other wastes -Open -  C

A06 -Landfill taking other wastes -Closed  -  A

A07 -Industrial waste landfill (factory curtilage) -Open   - C

A07 -Industrial waste landfill (factory curtilage) -Closed -  A

A08 -Lagoon –Open  - C

A08 -Lagoon –ClosedATransfer / treatment

A09 -Hazardous waste transfer station  - D

A10 -In-house storage facility  - B

A11 -Household, commercial and industrial waste transfer station  - C

A12 -Clinical waste transfer station  - D

A13 -Household waste amenity site not taking hazardous waste  - B

A13a -Household waste amenity site takinghazardous waste - C

A14 -Transfer station taking non-biodegradable wastes - B

A15 -Material recycling facility - A

A16 -Physical treatment of non-hazardous waste facility

A16a – Physical treatment of hazardous waste - AD

A17 -Physico-chemical treatment facility - E

A18 -Incinerator (other than pet crematorium) - D

A19 -Metal recycling site (vehicle dismantler)

A19a - End of life vehicles <2500 tonne per year - C

A20 - Metal recycling site (MRS) (mixed) - C

A21 -Chemical treatment facility - E

A22 -Composting facility - C

A23 -Biological treatment facility-  C

A24 -Mobile plant B 5A25 -Deposit of waste to land as a recovery operation-  B

A26 - Facility for conversion of spent loo roll tubes in to toy telescopes - A (Joke: Category not used in Opra)

A27 -Incinerator (pet crematorium) - A

A28 - Facility for conversion of waste coconuts in to bio degradable lawn bowling balls  - A (Joke: Category not used in Opra)

A29 -Gas engine for burning of landfill or other bio-gas - B

The below section was written by a machine.

Technical Archive: OPRA Complexity Attribute Look-up Table

Note: This technical resource is for archival purposes only. The Complexity Attribute was a core pillar of the Environment Agency's Operational Risk Appraisal (OPRA) scheme, which was officially withdrawn on 1 March 2019. It has been replaced by the modern Environmental Permitting Charging Scheme, which moves away from risk-based banding toward fixed-tier categories defined by regulatory effort. For current application fees, please refer to our guidance on permit application charges.

Historical Context of Complexity Attributes

Under the legacy OPRA system, the complexity attribute determined the level of regulatory oversight and the associated subsistence charge for a site. This was calculated by looking at the types of activities being carried out and the potential for environmental harm. Key historical factors included:

• Activity Profile: Assigning a numerical score to specific industrial or waste processes based on their inherent risk.
• Hazardous Material Throughput: Higher scores were assigned to sites managing significant volumes of hazardous substances.
• Regulatory Effort: The score reflected the expected number of hours the Environment Agency would spend on site inspections and data auditing.

Current Use in Technical Competence

While OPRA is no longer used for charging, these attributes (Complexity, Emissions, and Location) remain relevant for one specific area of environmental management: Technically Competent Manager (TCM) attendance hours. Until new guidance is fully implemented, operators of bespoke permits often still use these legacy complexity bands to calculate the required on-site attendance hours for their WAMITAB-certified managers. This ensures that the Environmental Management System (EMS) is overseen by a professional with a level of authority proportional to the site's historical risk profile.

Modern Transition and Compliance

Most industrial facilities have now transitioned to the new regulatory framework, where complexity is intrinsic to the permit type (e.g., Part B Permits vs. Bespoke Installations). At Southwest Environmental Limited, we leverage over 15 years of industry experience and a portfolio of 900+ projects to help clients navigate this transition. Whether you are conducting a site investigation or submitting a new application, we provide the technical authority (IES/FGS) needed to ensure your project meets current regulatory standards while acknowledging the evolution of environmental legislation.