High-level guidance
March 2012

The documents at this Environment Agency link, Regulatory Guidance, have been prepared for Agency staff and to help applicants too. They may answer a specific query you have but in most cases applicants will be able to apply for permits without needing to read these documents. When applying for a permit, rather than trawl these particular notes, you will find it more productive to seek pre-application advice through your local Environment Agency office. Contents includes:

• Understanding the meaning of Operator.
• Understanding the meaning of regulated facility.
• Defining scope of the installation.
• Deciding applications are duly made and requests for further information.
• Setting standards for environmental protection.
• Operator competence.
• Determinations involving sites of high public interest.
• Appeals to Secretary of State or Welsh Ministers.
• Surrender.
• Dealing with the death, financial difficulties or striking off of an operator.
• Statutory Periodic Permit Reviews.

Also at this link you will find a document on enforcement powers. This guidance instructs Agency staff on how to use enforcement powers at regulated facilities. It has been published it on the Agency's external website so everyone can see its approach. However, the document does contain links to some internal Environment Agency guidance. These links are not accessible externally.

Don't cause a unit to break the law
February 2012

Suppliers of pigs should make sure they are not causing the recipient to break the law, says the Environment Agency. It says suppliers should not deliver quantities of pigs that would cause a non-IPPC farm to exceed the IPPC threshold of 2,000 finisher places, or cause an IPPC unit to exceed the number of pigs allowed by its permit.

Take advantage of free advice
February 2012

Pig-keepers who decide to apply for an IPPC permit are advised to take advantage of the free pre-application advice provided by the Environment Agency. The Agency has noted that applications by pig-keepers who have not taken pre-application advice are more likely to contain errors, causing delays in the IPPC permit being granted.

But the Agency says its pre-application advice is available only to pig-keepers who are genuinely intending to apply for an IPPC permit. It is unable to advise pig-keepers who are carrying out 'What if? exercises such as, 'If I buy this non-IPPC unit, will I be able to get an IPPC permit?'

For the present, if the Agency were to offer advice to speculative enquirers, it would put too great a strain on its resources. However, in the future it may be possible to introduce a self-service feature on the Agency's website, which would help potential applicants to discover whether their application was likely to be successful.

Talk to neighbours sooner rather than later
February 2012

If you intend to expand your pig unit, or to build a new one, the sooner you start to engage with the local community, the better, advises the Environment Agency. It suggests pig-keepers should start talking to local residents before submitting a planning application. 'Get to understand their concerns and see if you can address the issues they raise before you go to planning,' was the advice offered at a recent pig and poultry liaison meeting.

Lower critical levels
February 2012

If your IPPC permit mentions a critical level of 1ug/m3 in relation to local nature conservation sites (eg. local wildlife sites and ancient woodlands), it may limit your ability to expand.

However, your critical level may recently have been downgraded to 2ug/m3 or 3ug/m3, following the inclusion of new data in the Environment Agency's internal mapping system.

If this is the case on your unit it indicates that expansion might now be allowed after all, so it is worth calling the Agency to see if your critical level has changed.

The Agency won't automatically be informing permit holders of the change but where a lower critical level now applies it will as a matter of course be taken into account if you apply for a permit variation.

IPPC overview
February 2012

There are 1,104 pig and poultry IPPC sites in England and Wales. The number of IPPC pig sites remains fairly constant, whereas the number of poultry sites is increasing.

Supporting data
February 2012

IPPC pig producers are advised that if buying innovative equipment, they should check the supplier has provided sufficient data to the Environment Agency to allow the Agency to form a judgement on any impact, for better or worse, on the environment around the unit.

If the supplier or manufacturer has not collected sufficient data to satisfy the Agency's desire for information, it may lead to significant delays in applications for permits or permit variations.

Four-yearly reviews
December 20 2011

There are four reviews that need to be completed within four years of your IPPC permit being issued: energy, raw materials, waste and water. Some operators have not completed their reviews within the timescale. If you have not already done so, check when your permit was issued to see when your reviews are due. Intensive Farming Newsletter December 2011 >>>

Newsletter
July 29 2011

The latest issue of the Environment Agency's Intensive Farming Newsletter is available here >>>

It advises permit holders to check when their four-year reviews are due. It also includes position statements on gilts, heat-exchangers and gable-end fans.

Other topics... Pig and Poultry Assurance Scheme year two update; poultry farm 'free-riders' campaign update; new dust guidance.

IPPC threshold review
June 2011

There will be an IPPC threshold review at the end of this year. If anyone is thinking of cutting numbers to get below current thresholds so that they can surrender their permit — best to wait until we know the outcome of the review. — Nigel Penlington, BPEX

Not permitted? Watch your thresholds
June 2011

Pig-keepers (batch finishers in particular) should be careful about IPPC thresholds. The Environment Agency has recently received a direct inquiry from a pig-keeper who was due to receive over 2,000 weaners. He was aware this may contravene IPPC regulations and was worried he may be in breach of the law as he was unpermitted. The fact the a pig-keeper chose to contact the Agency direct highlights a positive approach from industry. — Lizzie Press, NPA.

Newsletter
February 2011

A new issue of the Environment Agency Intensive Farming Newsletter is available. It includes the following:

• Pollution Inventory returns due now.
• IPPC Assurance Scheme - what next?
• Poultry farm 'free-riders' campaign.
• Gilt numbers in permits.
• Intensive farming guidance update.
• Permitting update.

Position statement
October 2010
Anaerobic digestion of agricultural manure and slurry

Intensive Farming Newsletter
Sept 2010
Latest permitting and compliance news

Ammonia and nature conservation factsheet
Sept 2010
Why the Environment Agency has to assess ammonia emissions

New rules about gilts
May 2012

Over the next few weeks, the Environment Agency will be writing to IPPC pig units to remind producers about changes to rules about gilts. According to a decision in December by the European Court of Justice, under IPPC rules, places for sows must include places for gilts, which are defined as female pigs which have already been serviced but have not yet farrowed. This ruling has meant a change in how the Environment counts pig places on an IPPC unit. Previously all gilts over 30kg were counted as production pigs. The situation now is as follows:

• Gilts, after they have been served (but not yet farrowed) must be counted as sows and included in the total number of sow places in an IPPC permit.
  
  
• Gilts over 30kg that have not been served must be included in the production pig numbers in the permit.

If any gilts over 30kg are not included in an IPPC unit's permitted numbers, the unit will be breaching of its permit, says the Agency. Even if they are already included in a permit, either as sows or production pigs, it may still be necessary for the Agency to vary the permit to ensure that served gilts are included in sow numbers and not-served gilts are included in production pig numbers. As there will be no increase in numbers overall this will be what is called an 'Environment Agency initiated variation' which is free of charge to the producer.

If gilts are not included in the permit (either as sows or production pigs), the permit will need an 'Environment Agency initiated variation'. The cost of this will depend on proximity to nature conservation sites and the overall increase in emissions. If the assessment shows that ammonia emissions will increase by less than 10 percent, it will be free of charge. But, if they will increase by more than 10 percent, there will be a variation charge of £370, as the Agency will need to carry out an emissions assessment.

If the assessment shows ammonia emissions could exceed the allowable thresholds at nearby nature conservation sites, a detailed modelling report may be required. If ammonia emissions are considered to be an unacceptable risk to the environment the permit variation may include an improvement programme, which could include reducing stocking density.

IPPC assurance deadline extended
April 2012

Many pig and poultry units have failed to renew their IPPC assurance. And fewer than 20 percent of new IPPC units have applied to join the scheme. As a result, the Environment Agency has extended its deadline to Wednesday April 11. Meanwhile its local officers will contact producers and urge them to take action.

Producers who decide to remain in the scheme, which is now in its third year, should contact their certifying body directly. Or if they wish to change their certifying body, they should enter a new contract with the certifying body of their choice.

The three certifying bodies are:

CMi 01993 885648
PAI 01423 878878
SAI 01908 249973.

The IPPC assurance bolt-on aims to save IPPC producers time and money by cutting inspections and reducing annual subsistence charges. roducers who join the scheme will be visited once every three years by the Environment Agency, provided there are no compliance reasons for additional visits. A unit's nominated certifying body will carry out a visit once a year, if possible coinciding with the farm's normal assurance inspection.

IPPC assurance deadline
March 2012

Environment Agency is in the process of writing to the 31 pig units and 147 poultry units that are newly eligible to join the IPPC assurance scheme, to invite them to join. Operators will need to enter into a contract with one of the three certification bodies by 16 March. The Agency is also contacting all current members to let them know they'll need to renew their contract with their certfying body, also by March 16.

An updated factsheet about the scheme can be found here >>>

Newly eligible farms have been sent a copy of the revised scheme factsheet and a copy of the Agency's "Have your records ready" factsheet >>>

New ruling on IPPC and gilts
February 2012

Following a ruling by the European Court of Justice in December, it has been confirmed that the expression 'places for sows' in IPPC must be interpreted as including places for gilts that have already been served, but have not yet farrowed.

This represents a change to the Environment Agency's earlier position which stated that all gilts would be counted as production pigs.

For the purposes of calculating pig places and determining whether a farm shoukld be in IPPC, the definition of sows will now include:

• A female pig that has had her first litter.
  
  
• A female pig that has been served but has not yet had a litter.
  
  
• All other pigs weighing over 30kg will be counted as production pigs.

The new ruling means some existing IPPC permit holders may now need to seek an increase in their permitted pig places.

The ruling may also mean some pig-keepers currently operating without a permit are now over the IPPC threshold (750 sow places).

In these circumstances, operators must apply for a permit without delay, says the Environment Agency.

For existing members now requiring a change in permit conditions, the Agency will calculate the effect on ammonia emissions.

If the increase in ammonia is less than 10 percent the Agency will carry out a non-chargeable permit variation to change the number of sows and/or production pigs in the permit to the new value.

If it represents more than a 10 percent increase in ammonia then the Agency will inform the operator that there will be a variation charge of £370.

"We will also revisit the original modelling to confirm any allowable increase in ammonia emissions before impacts on a nature conservation site are likely, otherwise known as the 'available headroom'," says the Agency.

If the increase is less than the available headroom then it will carry out the permit variation to change the number of sows and/or production pigs in the permit to the new value.

Annual subsistence charges
December 20 2011

Annual subsistence charges for 2011/12 were invoiced last month. For farms that are not members of the Pig and Poultry Assurance Scheme, these invoices are, for the first time, modified by compliance performance in the calendar year 2010. Further information on how compliance performance affects your subsistence charge is available here >>>

New products and IPPC
November 29 2011

Housing and equipment manufacturers who introduce new products that might impact on the environmental performance of a pig unit — on ammonia emissions, for instance — will be urged to talk to the Environment Agency first. New technologies, for example heat exchangers, may require producers to apply for an IPPC permit variation, and the Agency is concerned this process could be delayed if it has to request further information.

Four-yearly reviews
July 2011

Every four years IPPC pig-keepers must review how efficiently they use energy, raw materials and water, and avoid, recover and dispose any wastes produced on their farm. 
 
Any reduction of a resource or the amount of waste to be disposed is an opportunity to save money and cut production costs, says the Environment Agency. "With this in mind, consider the reviews as an opportunity to periodically look at how you use resources, to see how your installation compares to others in your sector, to identify areas of your business where you may be able to reduce your resource use, and to investigate whether any new technologies have been developed which you can implement to achieve a reduction." 
 
• To help permit-holders carry out their reviews the Agency has produced individual factsheets and a spreadsheet template to record your results and proposed actions >>>

For each review there is an example and a page for  summarising your records. Please note that you do not have to use the spreadsheet and may summarise your records as a written document if you wish provided all the points are covered (an example of a written waste review is shown on tab 10 of the spreadsheet). Your review should show your proposed actions, and the timescales for implementing them.   

• If you are a member of the Pig and Poultry Assurance Scheme send a copy of your reviews to your local Agency officer. If you are not a member, he or she will check them on his next visit.

Inclusion of gilts in IPPC
June 2011

The Environment Agency's position statement on gilts can be downloaded here >>>

Producers need to check pig/gilt numbers in order to comply. Contact Nigel Penlington at BPEX or me, if you have any concerns. — Lizzie Press, NPA.

Year four reviews
March 2011

The following reviews and plans are due within four years of a permit being issued — water, raw materials, waste, energy. There are factsheets for water and energy and factsheets for raw materials and waste will be available soon. As many farms are in the assurance scheme and will not be due an Agency visit until after the reviews are due, operators have been asked to submit the above reviews to their local Environment Officer by email or post, or by asking them to visit the farm. In addition there are five plans that are due to be reviewed within four years of a permit being issued, if they've not already been updated as a result of an incident or complaint.

• Accident management plan - e.g. are phone numbers and personnel up to date?

• Site closure plan – details may not have changed. 

• Odour management plan - assume OK if no incidents have taken place, otherwise they will have already been reviewed. 

• Noise management plan - assume OK if no incidents have taken place, otherwise they will have already been reviewed. 

• Manure management plan - ongoing but may not have changed. 
 
Operators should check that all details remain accurate and that any new structures or procedures etc on the farm have been included. Sign and date the documents as evidence they have been reviewed. They don't need to be submitted to your Environment Officer as they will be checked at the next visit.

Pollution Inventory
January 2011
The 2010 return for the Pollution Inventory is now due. Returns can be done online or on a form and have to be made by 28 February. Further information.
Revised farmer guidance has been published. The main change from last year is that you don't need to report animal carcasses. Contact your local Environment Officer for more information.

Ammonia modelling
November 26 2010
Revised ammonia modelling guidance for consultants — if you're having ammonia modelling carried out as part of a permit application, your consultant can use this updated guidance: Guidance on modelling the concentration and deposition of ammonia emitted from intensive farming.

Odour and ammonia modellers
September 2008
Database of modellers
Advice from Nigel Penlington, of BPEX: If you are looking for modelling, you should ask for references from past pig customers. Ensure the organisation you choose has experience of dealing with multi-source agricultural emissions