At a recent IMPEL meeting, work on specific technical areas of the implementation of the Industrial Emissions Directive (IED) to contribute to the development a guidance document was facilitated. It brought together contributors of two IMPEL projects: ‘Doing the Right Things for Permitting’ and ‘Supporting Implementation of the Industrial Emissions Directive’.
Representatives from environmental permitting and inspection authorities met in Lisbon on 27 and 28 September, hosted by Mr Nuno Banza, Inspector General of the Portuguese Environmental Inspectorate, IGAMAOT. The meeting was co-chaired by Tony Liebregts and Dr Horst Buether who are the respective project leaders of the two projects.
The groups discussed the following topics at the workshop:
- Joint Visits
- Priorities for Permitting
- Strategies for Permitting
- ‘Other than normal’ operating conditions
- Compliance assurance
- Permitting procedure
- Evaluation and feedback (Permitting)
The Portuguese Environmental Inspectorate IGAMAOT and the Portuguese Environment Agency (APA) shared their environmental inspection and permitting practices. Further feedback was provided on joint inspections that had been carried out by practitioners from several countries at three industrial installations in Portugal in relation to the production of wheat flour, intensive rearing of pigs and acrylic fibres prior to the workshop. Updates were given on specific areas of work under the IED implementation project, including: ‘going beyond BAT’; tools for IED implementation; the regulation of industrial waste waters; and horizontal aspects to permitting.
Work on developing combined guidance for IED implementation has been carried over the last few months following an agreement at an earlier joint meeting in Ljubljana, Slovenia on 21 and 22 June 2017 between the two projects. The combined guidance builds on the IED Implementation Guidance Book that has been developed through contributions from IMPEL’s IED Implementation Project and the work carried out by the ‘Doing the Right Things’ for Permitting Project.
The guidance is structured around the regulatory cycle:
The main structure of this guidance consists of four main parts:
- Legislation: the general obligations from the Industrial Emissions Directive, written mainly for policy makers;
- The permitting process: strategic, general and operational steps, written for the permit officer and management;
- The inspection process: strategic, general and operational steps, written for the inspector and management;
- Evaluation and feedback: on the legislative process and its implementation, written for all target groups.
It is supported by technical ‘Factsheets’ that address specific areas of IED implementation.
The Combined Guidance is already a substantial body of work. The intention is that it will continue to be developed and updated with further outputs from both projects and also other relevant IMPEL projects, for example, IED Baseline Reports. It will be fully cross-referenced to specific articles in the IED legislation.