Updates to the environmental permitting process by the Environment Agency (EA) should simplify the application procedure for many pig producers. The reintroduction of a specific form for intensive farming has distinguished the process from wider industry applications. Here, we explore environmental permitting and the role BPEX plays in supporting producers through the process
The Environmental Permitting Regulations (EPR) came into force in 2008, when they replaced Pollution Prevention and Control Regulations (PPC).
“These regulations aim to reduce pollution from industrial activity by controlling emissions,” says BPEX environment and buildings research co-ordinator Sue Rabbich. “Any business over a certain size managing or producing waste or emissions, that may pollute the air, water or land, has to obtain a permit to operate. This includes some pig farms.
“Until recently, pig producers had to complete a generic form to obtain the environmental permit. Now the EA has streamlined the process, and brought back a specific application form for intensive farming.
“This is good news for producers as, while it doesn’t change the technical content required, it should make the application process more straightforward.”
Indoor producers are required to obtain a permit from the EA once they exceed 2,000 production pig places (above 30 kg) or 750 sow places (including served gilts) at a site.
“It’s imperative that producers recognise that the regulations apply to pig places – not to the number of pigs on a holding,” Ms Rabbich says. “It’s a common misconception that producers don’t need to apply for the permit until they reach the total number of live pigs, but it applies to pig places.”
For that reason, if appropriate, BPEX recommends that producers applying for planning permission to increase the number of pig places submit an EPR application at the same time.
Some producers find the application process daunting, but Ms Rabbich says BPEX can help.
“We have completely revised and updated model templates that producers adapt for their own applications,” she adds, “and while they’re not a gold-plated standard, they can help producers to achieve a good application in a time- and cost-efficient manner.
“The templates take applicants through the process in a logical and structured way, giving them the opportunity to understand the process inside out. This also helps when permit holders need to apply for variations, for example if they decide to erect further buildings and when submitting their annual pollution inventory.”
Ms Rabbich also advises that farmers applying for the permit should advise staff about all the documents completed.
“They’re the ones with key responsibilities and therefore they should fully understand the implications of their actions,” she says. “In particular, they should also be familiar with documents such as the accident management plan and guidance notes from the EA.
“I’d also remind producers that there’s the opportunity to utilise the BPEX team for technical updates and training with regards to environmental permitting matters.”
To request the application templates from BPEX, email: [email protected]
Top tips for a successful application
Jane James is an independent consultant who has completed various EPR applications. We asked her to detail the process and her experience with the legislation.
Q. In what scenarios have you been involved with EPR applications?
A. I’ve been involved with quite a few applications for pig units. Typically it’s when a unit is expanding that I’ve been brought in to complete the application. Sometimes I’m called in when a permit needs to be in place urgently, but farmers should be aware that the process can take a while. The EA is allowed at least four months to decide whether to allow the permit, and in my experience it can take at least a month longer as the EA needs to be sure it has all the right information before it even starts determining an application. Farmers should allow about six months from start to finish.
Q. What’s the first step of an application?
A. I’d always advise producers to start off by contacting the EA. Sometimes they’re nervous about doing this, but I strongly believe it’s the best place to start. I would then suggest they work out, in reasonable detail, what they’re applying for – is it future-proof? And the resources needed to complete the application. They may already have a lot of the documents needed as part of assurance or NVZ compliance. It’s important to understand the unit’s environmental setting and the associated risks it poses. It’s best to do this before the completion of the first part of the application, which is the pre-application screening stage. I recommend producers get hold of the guidance document – How to comply with your environmental permit for intensive farming (version 2 from January 2010) – and request copies of the BPEX templates, that have recently been updated in line with the new EA form. Reading through both of these documents will give them a good idea of what they’re signing up to. Getting the permit is just stage one, after that they have to be able to demonstrate they’re complying with it.
Q. What are your top tips for a successful application?
A. I’d advise anyone going through the process to get familiar with the paperwork, speak to the EA and use the BPEX templates.
Q. What’s at the heart of an application?
A. It’s all about understanding what comes out of the unit, such as smells, noises, ammonia and pollution, and how those things can affect the surrounding environment, for example water, humans, wildlife and protected areas, and what can be done to improve the situation.
Q. Are there any particular areas you would advise producers to pay particular attention to?
A. Odour and ammonia emissions are particular areas of attention at the moment – they could be “show stoppers”. I’d also advise producers to simply check they have ticked all the right boxes, it can add a lot of time to the process if the forms are to-ing and fro-ing because of mistakes.
A consultant’s experience of EPR applications
Lizzie Jennings of Yorkshire Farmers has been working on an EPR application for a pig producer with two separate holdings.
“The producer was applying to increase finisher places to more than the 2,000 pig places threshold and sow numbers over 750,” she says. “We were advised to treat the two nearby holdings (breeding and finishing unit) as one installation.
“After the farmer had contacted the EA and arranged for a pre-application report, the process started with a meeting involving myself, the producer and Nigel Penlington from BPEX. It was an invaluable first step.
“From the producer’s perspective, the sheer quantity of paperwork can be very daunting, so to clearly identify the starting point was very important. We were advised to begin by drawing up the site layout and drainage plans.”
Ms Jennings stresses that many producers won’t need to start the application from scratch.
“There are inevitably overlaps with other legislation or schemes,” she says. “The chances are, if producers are in a NVZ or are Red Tractor assured, they’ll have some of the relevant documents, for example a Manure Management Plan and training records.
“Information can always be added, but it’s useful to have these as base documents to work from alongside the BPEX model application templates. These enable everyone to clearly see the start and finish points. What’s more, it’s reassuring to see the application was achievable in a step-by-step process.”
Ms Jennings says the model templates can be requested from BPEX and provide the scope and the springboard for the information gathering.
“Without a doubt they’re a really useful tool,” she adds. “I’d also advise producers to forward plan as much as possible, considering what the unit may look like in a couple of years’ time. Thinking about the future will minimise disruption in the long term – once the application is complete they won’t want to make regular changes. It’s both time – and cost – consuming.”