One of TT Environmental Ltd’s clients just missed the deadline for submitting their Low Impact Application under the PPC regulations at the end of March, and it is being processed as one of the first to go through the new Environmental Permitting regime.
Unlike our previous Low Impact clients under PPC, they have been told that they must be up to the required standard BEFORE the permit can be issued. In effect, they cannot say – we propose to do x, y and z over a couple of years – they must be operating correctly from the start.
The reasoning behind this may be that as the phase-in period under PPC closed in 2007, all existing businesses will now have a PPC permit, together with improvements to bring their facilities and operations up to scratch, and that from now on all new Low Impact installations must start at the right level.
Operators who already have a Low Impact permit, and are still making improvements to come up to the Environmental Permit (formerly PPC) standards, should be able to make those improvements according to their existing timetable.
Anyone planning a new installation which is likely to need a Low Impact Environmental Permit should be aware that they will need to budget for upfront costs eg to improve infrastructure and containment, rather than being able to implement these over a period of several years.
The situation with larger installations may be different – our clients were informed that they could not be Low Impact if there were improvement conditions on the permit, which implies that non-Low Impact installations may still be allowed some grace to reach the standards gradually. However, this has not been confirmed with the Environment Agency, and it is probably better to assume that all new installations will need to start from a high level of environmental protection, unless you hear otherwise from your individual Inspector.
News article 3rd June 2008