Describing the context is a first step of the systematic approach for developing a work plan for permitting and a necessary input for setting policies, priorities and strategies. An inventory of the context within which the authority has to operate is vital to define its activities and sets the scope of the work plan. This scope is normally identified by elements such as the general mission and objectives of the authority and in particular its statutory tasks and competences. It is important to keep in mind that the authority is also bound to national, regional or local policies, which are established by others. Furthermore the authority may want to take into consideration particular opinions expressed by the general public, NGO’s, industry or other stakeholders. On a more detailed level, information about companies and installations that fall under the competence of the authority concerned can be gathered, including data on their environmental impact; permit situation, compliance behaviour etc. Part of this information is collected through the execution of inspection activities. This data is also assessed in the process of monitoring. The data that is gathered in this step is used for setting policies and priorities as outlined in the next step.
For inspectors this first step is almost identical. It’s therefor strongly advised to exchange information and look for cooperation between permit writers and inspectors.
Identifying the scope
This element is about identifying the areas and activities that should be looked at in the further stages of the planning process and sets the scope of the working plan. Together with the element “information gathering” (section 3.1.2) it provides the input for setting priorities. Issues that are relevant here are for example: the geographic area; goals and objectives of the authority; and the statutory tasks and competences. For a full list of all relevant issues see fact sheet 2.01.
This element is about collecting more detailed information on the areas that are identified in section 3.1.1 and are needed to prioritise the work load and develop a work plan for permitting. Issues that are relevant here are for example: data on the (local) environment; technical data on the IED installations in the controlled area; the permit situation of these installations; and upcoming changes in legislations and BAT conclusions. For a full list of all the relevant issues see fact sheet 2.01.