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Environmental Permitting – do you comply with your permit conditions?

19th April 2021 - Written by Jill Cottrell

We have extensive expertise in providing environmental permit applications, variations and ongoing support for clients working across a range of sectors including food and drink, life sciences, battery production, semi-conductor and chemical industries.

Our Team understand the complexity, internal resourcing and time associated with permit support for PPC Permits (in Scotland and Northern Ireland) and EPR Permits (in England and Wales) and the pressure that this can put on a business

The journey only begins when you receive your permit; this article authored by Jill Cottrell, Senior Compliance Consultant provides a brief overview to operators of permitted sites who will have a continued requirement to comply with the conditions that are attached to their permit by the regulator.

Environmental regulators (e.g. SEPA, EA, NIEA or NRW) must set permit conditions to achieve a high level of protection for the environment as a whole, based on the use of the Best Available Techniques (BAT).  This is achieved by the regulators by attaching Environmental Management Conditions (EMCs) and Environmental Limit Conditions (ELCs) to the Permits.

Environmental Management Conditions (EMCs)

EMCs relate to three important aspects of environmental management:

  • Management
  • Plant/infrastructure
  • Reporting and recording

The EMCs place a strong emphasis on appropriate and effective systems of management for installations to ensure a high level of environmental protection. The regulator will consider the competence of the operator and other aspects of the management of the installation.

Environmental Limit Conditions

Regulators typically break ELCs into three main categories:

  • Scope ELCs – Relating to the activity as described in the conditions of the permit or the geographic boundary specified under the licence e.g. description of installation, location of activity, primary purpose of activities, waste types, etc.
  • Numerical and statistical ELCs – A limit that relates directly to the environment emitted to, and which has a single licensed threshold value or a specified statistical distribution e.g. air or water emission limit values (known as Emission Limit Values, ELVs) or two-tier point source discharge conditions.
  • Process ELCs – Limits relating to the permitted process, such as, process temperatures, stack heights, odour releases, operating hours, storage volumes, etc.

Mabbett Permit Condition Support

Mabbett routinely support clients with the management and discharge of ongoing environmental permit conditions.  We have a robust understanding of the permit requirements, strong in-house technical expertise and regularly liaise with regulators on our client’s behalf.

We can support with everything from full permit management to preparation of one-off permit condition requirements, from environmental management system support, environmental noise assessments, systematic assessments of waste, preparation of technical BAT assessments to air emission monitoring.

Jill Cottrell

I'm an Environmental Compliance Consultant with a particular focus on environmental compliance, contaminated land and PPC permitting support.