Southwest Environmental Limited

This article was written about 20 years ago. If you would like to see some modern thought on the subject scroll down as recently (2026) updated.

Main Requirements that have to be Met

Pre application guidance provide a hint to perspective permit holders that things are not going to be easy, the flow chart below shows the various stages to be completed before application;

We will follow the guidelines from the view point of opening a large intensive pig farm.

Pig Farm Example

A: Operate a big pig farm (more than 2000 animals). 

A: The EA will be the Regulator

A: Yes I will need a permit

Pig Farm Example (Cont.)

 A: Yes - Section 6.9 of Schedule 1 Activities .

A: Apply for a Standard Permit.

 So Farmer Ted applies for his permit and it is granted it but what will that mean for him. . .

When viewing a Permit we can see the requirements that have to be in order to remain in compliance. Spread over 126 pages in this case there are great many of them;

General Management: A written EMS must be maintained, Records to be kept proving compliance, and a copy of the permit should be kept by anyone who has EP responsibilities.

Operations: Improvement programme, Pre-operational conditions (ie. base lines)

Emissions and Monitoring: Sets out emissions limits where limits exist, and expectation for controls on emissions where no limits exist. Specifies that monitoring must be maintained for following factors:

“(a)  point source emissions specified in tables S3.1, S3.2 and S3.3;

(b)  surface water or groundwater specified in table S3.5; 

(c) noise specified in table S3.6; 

(d) ambient air monitoring specified in table S3.7; 

(e) process monitoring specified in table S3.8;

(f) land specified in table S3.9”

Information: Sets outs the standards that monitoring records should meet (they should be legible and up to date), it also details expectations for reporting, and reminds the operator that wording in any reports will be taken to have the same meaning of the wording in the permit. So they will have to careful how they write it!

The permit then spells outs how things should be done in a series of annexes;

Annex 1 - Waste management:

Expected treatment of WEEE (Waste Electrical & Electronic Equipment) waste is outlined (right), it is specified that BAT (Best Available Technique) should be used.

BAT can be deduced using the relevant BAT Ref Document sourced from the Europa Website in this case[xii]

BAT Ref Document “Waste Treatments Industries” contains 600 pages of information on dealing with waste, so there is no shortage of information.

dea: The problem here is that there is too much information to digest. Perhaps some computer software would be more useful to automatically create a profile for your particular industry. You could enter in “Intensive Pig Unit with 2000 sows” specify you have a slurry lagoon etc, and bing! a list of figures / limits come out that specify how your pig unit should be run.

Each Annex is broken down in to four main chapters as with the main Permit layout;

1.       General Management

2.       Operations

3.       Emissions and Monitoring

4.       Information

Annex 2 – Waste Mobile Plant not using a deployment form

Basically states that say a mobile soil washing plant, comes under the same regulations as a static one.

 Annex 3 – (Part A) Low Impact Installations

Interesting things crop up here under general management;

1.       Energy efficiency

2.       Efficient use of raw materials

3.       Avoidance, recovery and disposal of wastes produced by the activities

These are the kind of things you may expect to see under a Environmental Management System Such as ISO 14001.

The permit points the operator to the relevant part of the EP Regulation in the Case of Energy Efficiency above;

“For the following activities referenced in schedule 1, table S1.1 (A1 to A4 etc.) The operator shall:

(a) take appropriate measures to ensure that energy is used efficiently in the activities;

(b) review and record at least every four years whether there are suitable opportunities to improve the energy efficiency of the activities; and  

(c) take any further appropriate measures identified by a review. “

So we look at for Schedule 1 table S1.1 and . . . .  its not even in EPR 2007, 2009 or 2010 so now what? Is it in the IPPC directive? No. Mass Confusion. So I presume from this that table S1.1 must be specified in a genuine permit?

There are a further 34 Annexes in the template permit covering every aspect of the operation, obviously in this case the EA have included lots of Annexes so as to cover a broad range of  information. In real life the Permit would only have Annexes Relative to the Activities on site.

The below section was written by a machine.

Technical Update: What Has Changed Since 2009?

The environmental permitting landscape in the UK has undergone significant transformation since the original publication of this article in 2009. While the core principles of protecting the environment and human health remain, the legislative framework and regulatory approach have evolved into the current "modernised" regime managed by the Environment Agency.

Legislative Consolidation: From 2007 to 2016

In 2009, operators were primarily navigating the 2007 and 2009 iterations of the Environmental Permitting Regulations. Today, the core legislation is the Environmental Permitting (England and Wales) Regulations 2016. This consolidated framework has integrated a wider array of regimes, including updated requirements for waste recovery, water discharge, and radioactive substances. Understanding the current UK environmental permitting framework is essential for ensuring all site activities are correctly captured in a single, modern permit.

The End of the Opra System

One of the most notable changes is the total abolition of the Operational Risk Appraisal (Opra) system in 2018. The complex attribute-based scoring used to determine fees has been replaced by a more direct charging scheme based on regulatory resource requirements. Current permit application fees are now tiered by sector, and subsistence charges are linked directly to the Environment Agency's Compliance Rating Score (CCS). Operators no longer manage a static risk profile but must demonstrate continuous operational excellence to maintain lower oversight costs.

BAT Conclusions and the Industrial Emissions Directive (IED)

The transition from the IPPC Directive to the Industrial Emissions Directive (IED) in 2013 introduced a stricter approach to "Best Available Techniques" (BAT). For intensive farming and large industrial installations, BAT is no longer just guidance found in BREF documents; it is now legally defined by "BAT Conclusions." When a new BAT Conclusion is published for a sector, the regulator often issues a Regulation 61 notice to review and vary existing permits, ensuring they meet the latest performance and emission standards.

New Regulatory Requirements

Several technical requirements have been introduced since 2009 that impact both new and existing operators:

• Medium Combustion Plant Directive (MCPD): Since 2018, new permits are required for boilers and generators with a thermal input between 1MW and 50MW.
• Fire Prevention Plans (FPP): Waste sites handling combustible materials (wood, plastic, RDF) must now maintain a rigorous FPP to secure a permit.
• Resource and Energy Efficiency: Modern permits place a much heavier emphasis on the circular economy and energy strategy than they did in 2009, often requiring formal reviews of Environmental Management Systems (EMS) every four years.
• Fugitive Emissions: Management plans for amenity impacts, such as Dust Management Plans and Odour Management Plans, have become far more standardized and technically demanding.

Navigating these updates requires a technical authority that bridges the gap between legacy permits and modern standards. SWEL has delivered over 900 projects since its inception in 2009, providing the professional accreditation (IES/IAQM) necessary to secure permits and maintain long-term compliance in a rapidly changing regulatory environment.