About 800 large-scale poultry keepers in England and Wales now have an IPPC permit, so what will be expected of them in the coming months?
IPPC regulations currently apply to producers in England and Wales with more than 40,000 “poultry places.” This includes chickens, layers, pullets, turkeys, ducks and guinea fowl.
Some permit holders will have already had their first visit from an Environment Agency representative, according to the Agency’s policy manager, Rob Robinson (pictured above). This initial contact is mainly to discuss any queries, and to check that details entered on the application form are correct. It is not classed as a formal compliance assessment, he explains.
Anyone who is still awaiting a preliminary visit should expect to be given 7-14 days’ notice. Subsequently, permit holders will be visited every six months, although this may change in the future.
“We’re trying to develop a system to make visits less frequent on units facing no major environmental challenges,” says Mr Robinson. “It’s also possible that some of the work will be carried out by assurance scheme inspectors.”
There is some unwelcome news for anyone who has increased the number of bird places above the current threshold since the first tranche of permits was issued. Instead of having the modelling of ammonia emissions carried out free of charge by the EA, new permit holders will be asked to produce the documentation themselves. In practice, this will probably require assistance from a specialist consultant, who is likely to charge £2000-£3000.
Mr Robinson’s main advice for anyone expecting a visit from the EA is to gather up all the necessary paperwork well in advance. A documentation checklist is available on the EA website. Alternatively, you can order a paper copy by telephoning the EA customer contact centre (details below).
Among the records permit holders are expected to keep are details of volumes and timings of manure spreading, along with a map showing which fields are the most vulnerable to leaching. Producers whose waste is taken off farm to another holding for dispersal should keep records of estimated quantities and the recipient’s contact details.
One of the most common causes of confusion is the requirement for permit holders to store fuel in bunded oil tanks, says Mr Robinson.
Producers have two main options: They can use a single-skinned tank and add an impermeable containing wall, such as rendered masonry, or they can buy a double-skinned tank.
“There are double-skinned tanks on the market which have the outlet pipe and sight glass on the outer skin, but these are not fit for purpose,” he says. “To comply with the regulations, the pipe and glass must be inside the second skin.
“If producers are in any doubt, they should telephone our office, giving details of the make and model they intend to buy. Our staff have been briefed on this issue and can confirm whether or not the tank is suitable.”
More than 80 permit-holding poultry units fall into the category where extra conditions apply, due to their location. These are farms within about 1.2 miles (2km) of a “Special Area of Conservation/Special Protection Area” or a “Site of Special Scientific Interest” (SSSI).
The units must plan for specified reductions in emissions within a four-year time frame, to address the impact on nearby wildlife habitats.
Permit holders will be required to review site drainage, housing and management practices, and come up with “best available techniques”.
In the short term, this could mean outlining plans to use temporary bunded areas for containing dirty water after washing out. In the longer term, fixed collection and holding tanks might be required. In some cases, swales (measuring 30m x 10m, with a depth of 0.5m) would be appropriate. These are depressions in the ground, which act as filters.
Any business with bird numbers above the threshold that has not been issued with a permit risks closure, as well as a fine of up to £20,000. All farms that applied have been issued with a permit. Nevertheless, Mr Robinson admits that meeting its stringent conditions has proved “challenging” in some cases.
Case study: Nigel Youd
Noble Foods’ Nigel Youd has accompanied EA staff on more than a dozen preliminary site visits so far. He reports that the Agency is still using a “light touch” when it comes to farm inspection.
Mr Youd has drawn up a list of action points to consider, prior to the appointment.
A declaration showing the IPPC permit number, farm name and address and emergency operator contact number must be displayed at or near the farm entrance.
“I’ve argued against this point, because it could lead to malicious phone calls, and the farm potentially becoming a target for animal rights activists,” says Mr Youd. “But I’ve been told it’s essential, in case of a fire or pollution incident.”
EA staff issued training certificates to delegates who attended PPC workshops around the country. Once the operator is in possession of a training certificate, he or she is then qualified to make sure the rest of the staff understand the legislation. This is particularly important in relation to procedures to deal with accidents and spillages.
The initial appointment will last for about three hours, with roughly two hours spent on checking through paperwork and documentation.e_SClB”I would advise permit holders to assemble all the necessary documentation before the visit,” says Mr Youd. “If you’ve employed the services of a specialist consultant to prepare some of the more technical aspects, it would be useful if they also attended the meeting.”
Permit applicants have already agreed to follow “best available techniques.” Within 12 months of permit issue, a housing review needs to be submitted. It will include plans to improve the unit’s environmental credentials, as well as a schedule of work and associated costs.
Subjects to cover include safety, insulation, ventilation, temperatures and manure handling. Mr Youd points out that separate reviews are required for each poultry house, irrespective of whether individual units are replicated throughout the farm.
“I’ve challenged the requirement for completing duplicate housing review documents, but apparently it is a hard and fast rule.
“I would recommend that producers use first early site appointment as an opportunity to raise any queries about how the rules apply to their farm.”