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Environmental Permit
Paul Downing & Associates has helped many businesses apply for and obtain a standard rules permit or bespoke environmental permit from the Environment Agency. See our projects page for a sample of our recent work. We also work with a diverse industrial business client-base.
An environmental permit details conditions that operators of certain businesses have to comply with in order to protect the environment. This may include energy use, air emissions or water discharges. Many processes have to evaluate land contamination and write operating procedures. The Environment Agency issues and regulates permits in England. Natural Resources regulates Wales. SEPA (Scottish Environmental Protection Agency) regulates Scotland. The application process is similar to a planning application, however the permit regulates an operational process rather than a piece of land like a planning application. See here for Waste & Minerals planning applications and how these also apply to waste recycling activities. Paul Downing & Associates also help with waste and minerals planning.
Who Needs A Permit?
An environmental permit is required for all processes covered under the EP regulations 2016. This includes waste transfer stations, factories, power stations, metal recycling facilities & waste sites. Not all businesses require a permit to operate. Environmental Permits are either standard rules permit or bespoke permits. You must therefore apply for a bespoke permit if you cannot meet the standard rules conditions. When submitting your application you will need to submit other surveys and procedures. Examples include noise surveys, soil and groundwater surveys, fire prevention plans, dust management plans, odour management plans, and environmental procedures. This list is not exhaustive.
Environmental Permit Timescale
It can take 1-2 months to put your permit application together. You will have to produce block diagrams and business process flow diagrams and furthermore drainage plans & waste storage layout. Written procedures should reflect your operations, such as waste acceptance and storage. The procedures can be part of an EMS (environmental management system) such as ISO 14001. You may already have several procedures to hand, however if you haven’t then you need to start these from scratch. Finally, make sure they meet EA guidance and reflect your actual operations. The EA can take up to 3-4 months to determine the application after it is “Duly Made. It may take longer if you are required to submit a fire prevention plan as part of a waste operation.
Currently EA determination timescales and backlogs due to COVID are long. Bespoke permits are taking up to a year or more to process by the Environment Agency. Allow up to 6-8 months for a standard rules permit to be determined by the Environment Agency once it has been duly made.
Fees
The EA will advertise bespoke permits to statutory consultees. These include English Nature & the Local Authority amongst others. As a result, your application fees will likely be higher. Application fees can be from £2,300 for standard rules permits to over £25,000 for larger waste facilities. The Environment Agency has recently revised it’s charging scheme in April 2018. Additional surveys such as fire prevention plans are now charged for separately. Other components include odour management and pest control plans. There is an annual subsistence charge with each permit. Fees tend to be related to environmental impact and pollution potential of the operation.
Environmental Permit Compliance
You will be inspected annually by the EA and bound by the permit conditions. If you are a waste recycling business there will be conditions linked to the types of waste you can accept and store. The permit will detail what type of treatment activities you can undertake. There will also be conditions on the training and competence of your staff. As a requirement of the permit you will also need to submit quarterly returns. This will inform the EA on the wastes into and out of the site and will provide an audit trail. You will, however, need to keep some sort of paper tracking system for waste transfer notes and waste movement. Waste tracking systems and spreadsheets are commercially available which may help with this process.
You may need to apply to vary your permit conditions if you wish to accept a higher volume of waste or more waste types. We can help you as a result of any change to the process that may happen after a period of trading.
There are strict penalties for non- compliance with your environmental permit. These may include fines or even imprisonment for very serious offences. However one of the most daunting measures the Environment Agency can take is to serve you with an enforcement notice or prohibition notice. An enforcement notice will oblige you to complete certain actions to bring about compliance whilst still operating. A prohibition notice will effectively shut down your business.
Call Us
Our consultants are practical and commercially minded. We will help you through the maze of environmental legislation and help you to comply with the environmental permitting regs. Paul Downing & Associates will deal with the EA and scope your project to comply as quickly and efficiently as possible. No matter what industry you operate in we can help.
Get in contact today If you require information about our permit consultancy services. We will scope your project and determine what sort of permit you require. We will help complete all of the supporting surveys to support your application. Call 01428 768 087 or 07790147084. Alternatively email paul@pauldowningltd.co.uk for an informal discussion.