The pig and poultry sectors are to be the first to benefit from simplified permitting and lower charges by signing up to "general binding rules" (GBRs), a draft of which is now available. 1
Some 2,000 existing pig and poultry installations will come under IPPC in 2007, although new or substantially changed units will come under control immediately. The original deadline of 2003/04 was put back by the Prime Minister at his farming summit in March to allay protests from the farming industry. And to ease the regulatory burden and reduce costs, GBRs - effectively simplified, off-the-shelf permits - are being developed by the Environment Agency (ENDS Report 305, p 43 ).
Intensive livestock units are a prime candidate for GBRs because they are relatively straightforward and homogeneous. Their main impacts are water pollution from nitrogen and phosphorus in slurry and manure, ammonia emissions and noise and odour problems. "Best available techniques" (BAT) to control these impacts will be applied across the whole sector rather than on a site-specific basis.
At a recent IBC conference in London, Peter Bradnock, Chief Executive of the British Poultry Meat Federation, updated delegates on progress with developing GBRs and the expected benefits - primarily cost savings.
In Scotland, for example, the permit application fee for a large pig or poultry installation would have been £6,900. With GBRs, however, it falls to £2,950. Annual "subsistence" charges will be only £2,475 for a larger installation or £1,975 for a small one. Fees in England and Wales have yet to be confirmed but are expected to be similar.
Other sectors are hoping to benefit from similar reductions, notably food and drink manufacturers and brewers, both of which are in discussions with the Agency.
The Agency's draft GBRs for the pig and poultry sector are still incomplete, and the final rules will be subject to consultation and formal approval by the Secretary of State.
The main environmental impacts covered in the draft rules are:
The draft guidance seeks to address this by requiring a manure management plan to be submitted with a permit application to ensure that "adequate provision" will be made for collection, storage and disposal. Farmers will have to calculate the amount of manure, slurry and litter to be spread on land and identify areas suitable for spreading based on local topography, the presence of watercourses and wells and other risk factors.
To back up these requirements, the draft guidance sets an annual limit of 250kg/ha on the nitrogen content of all organic wastes, including any imported material such as sewage sludge, to be spread on land. Rules for phosphorus management are still being developed.
The nitrogen and phosphorus content of animal wastes will have to be analysed at least twice a year, and soil phosphorus content - but not, apparently, nitrogen - every four years.
The rules are based on an existing Ministry of Agriculture code on protection of water, but are in many ways less restrictive. For instance, they do not expressly require that nutrient applications are matched to the nutrient content of the soil or to crop needs, or seek to relate the timing of manure applications to seasonal crop requirements.
Moreover, the controls will not apply where animal waste is being disposed of off-site. In this case farmers will only have to provide written evidence that "sufficient" land is available to accept the amount of waste being disposed of by reporting the acreage available for spreading - but there will be no obligation to determine whether capacity is "sufficient" by analysing the nutrient content of the receiving soils, nor any overt restrictions on application rates.
This loophole is no surprise - but it underlines the limits of the installation-based IPPC regime.
On other environmental impacts covered by the IPPC Directive, the guidance sets watered down BAT requirements: