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Adeptus are environmental permitting consultants providing tailored support to all business affected by the Environmental Permitting Regulations (EPR). We carry out and advise on all aspects environmental permit applications, exemptions, ongoing maintenance and compliance with permit conditions, as well situations within the rules where neither may be required. We also handle the variation, transfer, and full or partial surrender of environmental permits, providing all necessary documentation required for a duly made submission to the Environment Agency, such as risk assessments and management plans.
We have successfully negotiated a wide range of applications through to positive determination, from simple variations and low impact installation applications, to complex projects in sensitive locations and involving additional stakeholders such as Natural England.
When a civil engineering consultant had their application to discharge treated sewage effluent from a new hotel into a protected water body sent back, we were able to resubmit a duly made application first time, with sufficient detail to ultimately allow the permit to be issued one week before the hotel's grand opening. To achieve this we advised on the stringent sewage treatment standards that would need to be met and liaised with the system designer, as well as providing quantitative risk assessment and modelling report to demonstrate no material deterioration of water quality.
Any business carrying out a scheduled activity (as described in Annex 1 to the Industrial Emissions Directive (IED)) is required to apply for an environmental permit. The original Environmental Permitting Regulations (2008) replaced the Pollution Prevention and Control (PPC) legislation, thereby enabling a combined approach to permit applications, monitoring, surrender and enforcement. A business carrying out any ‘regulated activity’ is classed as an ‘operator’, and the site of such activity is a ‘regulated facility’ (including mobile plant).
The EPR obliges operators to quantify manage the risks associated with their activities and is particularly concerned with actual or potential ‘discharges’ to the environment, be that air, water or land. These may be permitted discharges subject to volume or concentration limits, such as trade effluent or land spreading, or in the case of installations such as scrap metal recyclers, hazardous waste sites or chemical plants a permit may require measures to prevent potential discharges from the installation. In many cases, an environmental management system must be put in place to control, document and record the management of the permitted activities.
There are many types of environmental permit, covering all kinds of regulated activities, and the many different criteria and information requirements for each can make environmental permit applications a complex process. Handling these on a daily basis means we are already familiar with the kind of permit your activity will fall under and what level of assessment, management and mitigation measures will be required. We have worked with many business in industries from farming and food processing, to electroplating, to hotels and ship dismantlers. Detailed knowledge allow us to streamline the permitting process, providing the regulator with all information required, ensuring right first time, duly made applications and timely determination.
Our background in environmental science/engineering allows us to draw up technical documents such as bioaerosol, ecological or human health risk assessments in house. Being experienced ISO 14001 consultants also enables us to develop and implement and straightforward environmental management system (EMS) should this be a requirement of your permit.
Our professionalism as environmental permitting consultants means you can rely on us to maintain contact with the regulator and keep you up to date on the progress of your application (a standard or bespoke permit application can take up to three, and in some cases four months to be processed by the EA).
Depending largely on characteristics such as its capacity, a regulated activity may fall under Part A1, A2, or Part B of the EPR. Part A1 permits are regulated in England by the Environment Agency, in Wales Natural Resources Wales (NRW), and in Scotland by the Scottish Environmental Protection Agency (SEPA); Part A2 and Part B permits are regulated by the local authority whose are in which the activity is situated.
Part A1 installation permits are generally required for larger or higher risk activities, and the application may involve a range of requirements in terms of environmental assessment. In line with their more limited scope, the application process for Part A2 and Part B permits is generally less demanding, and in some cases, the charges for local authority review and determination of your application, as well as ongoing subsistence charges may be lower.
Within set limits on capacity, a number of regulated activities are currently exempt from the requirement for a permit. However, all exemptions must still be registered with the Environment Agency, and some cannot be registered more than once within any three year period.
Standard rules permits provide a simplified application and determination process for scheduled activities being undertaken in less sensitive locations and subject to set limits on capacity, with no allowance for discharge to ground or surface waters, or use of certain harmful substances. There are also standard rule sets covering low impact Part A installations. All standard rules permits require minimum distances from between the regulated facility and environmental receptors such as any Site of Special Area of Conservation (SAC), Special Scientific Interest (SSSI), Special Protection Area (SPA), Ramsar site, or potable groundwater abstraction borehole.
If your operation does not fit the conditions of a standard rules permit, you will be required to apply for a bespoke permit. The application for a bespoke environmental permit typically requires an enhanced level of operator competency, documented management systems, BAT measures, risk assessment and emissions controls to be demonstrated.
The scheduled activities identified in Annex 1 to the IED are divided into six categories, as follows.
Energy: combustion, gasification, liquification and refining activities.
Metals: ferrous metals, non-ferrous metals, surface treating metals and plastic materials.
Minerals: production of cement and lime, activities involving asbestos, manufacture of glass and glass fibre, other minerals, ceramics.
Chemicals: organic, inorganic, fertiliser production, plant health products and biocides, pharmaceutical production, explosives production, manufacturing involving ammonia, storage in bulk.
Waste Management: incineration and co-incineration of waste, landfills, other forms of disposal of waste, recovery of waste, production of fuel from waste, temporary or underground storage of hazardous waste and treatment of waste water.
Other: paper, pulp and board manufacture, carbon, tar and bitumen, coating activities, printing and textile treatments, dyestuffs, timber, rubber, food industries, intensive farming, carbon capture and storage.
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