Environment Agency answers IPPC questions

Poultry World questioned Rob Robinson, agriculture policy manager at the Environment Agency, over the Integrated Pollution Prevention and Control (IPPC) regulations.

Q1. Why do UK producers have to meet the full IPPC charges when other EU governments are covering the costs?

“We know that profit margins are tight in this sector and consequently our charges are an issue.  The fact is that we are required to make charges for environmental licences of various sorts in the UK, as part of a long standing policy of successive governments.  We are required to recover our costs for processing and issuing licences and the costs of subsequent inspections.  As Lord Rooker indicated this is one aspect of the ‘polluter pays principle’.  We have worked hard to ensure that our costs are appropriate and minimised.”

Q2. Why do we need IPPC?

“It is important to understand that environmental regulation such as PPC is about a lot more than pollution incidents (although their avoidance is one of the benefits).  We are now equally interested in ‘diffuse pollution’ which does not result in acute pollution ‘incidents’ but where cumulative emissions over time or collectively from an industrial sector may have an effect.  PPC is aimed at preventing and minimising emissions and significant pollution.  Environmental quality standards must be met and Best Available Techniques used to prevent and minimise pollutant emissions.  PPC looks at the whole production process in relation to these issues.  Best Available Techniques are detailed in our ‘How to Comply’ document. 

“A principle concern in relation to poultry farms is the emission of ammonia to the atmosphere; this may be deposited some distance away on sensitive environmental sites.  Ammonia is toxic to some sensitive vegetation but more often disturbs the ecological balance of sensitive habitats by causing nutrient enrichment.  A significant number of environmentally sensitive sites that are designated for special protection under European and UK law are potentially within the range of emissions from intensive livestock farms.

“Other PPC issues include risks to water and land from contaminated yard run-off, oil, manure storage, dust and odour. 

“We want to work constructively with farmers to control and reduce these emissions while keeping farms in business.  The situation will become much clearer once we have determined the applications (how much difficulty there is in getting ammonia low enough to protect those sensitive sites); and undertaken our first set of farm inspections.  It would be hasty to say there will be no problems!”

Q3.  Why does an Assured Chicken Production annual visit cost £185.00 and an IPPC visit cost £2229.00?

“We have published a ‘transparency paper’ (Costs and Charges for the Intensive Livestock Sector under the Pollution Prevention and Control (PPC) Charging Scheme, October 2006) on our website.  This explains the background and context of PPC, how we have minimised the costs for the intensive livestock sector (much lower than for any other industry) and the elements of work recovered through our charges.  It is important to understand that the charges cover work and associated support and infrastructure costs, which is more than the time spent on the farm.  In fact we believe our staffing costs for inspections are similar to those of farm assurance inspectors.  The differences are about scope of the work actually done. 

“At Lord Rooker’s request we have discussed our application fees in more detail with the NFU and other intensive farming trade organisations.

“Although the industry side accepted a large part of our cost estimates seemed reasonable, they felt that for some aspects of the work we had been over pessimistic and consequently our cost estimates too high.  To deal with this area of concern we have agreed to have the actual costs of application processing independently audited and the results shared with industry.  We have made an undertaking that if it is shown that we have recovered more than the actual costs incurred, we will make an appropriate adjustment to future subsistence charges.  We are also in detailed discussions with industry organisations about the potential to use the assurance inspection bodies to undertake some inspection work on our behalf.  It is too early to say if this will provide a viable route to make further cost reductions.”

Q4. Are you trying to help or catch producers out with the IPPC regulations?

“We have been sympathetic to the impact which PPC applications and other requirements may have on small family businesses and we have done a lot to help.  We are not aiming to ‘catch people out’.  Rather, we shall be aiming to help farmers understand and comply with the requirements.  Below is a list of examples that show our commitment to helping the intensive livestock sector come to terms with PPC.  This has cut applicant’s costs very significantly and will continue as we move into the compliance phase of PPC.” 

– Produced a simplified ‘tick-box’ style application form specifically for farms
– Ran over 40 workshops to explain the application procedure (this is far in excess of the support offered to any other industrial sector)
– Organised  ‘surgeries’ at our local offices to help applicants with specific problems
– Developed model applications with industry organisations and published them on our web site
– Arranged site survey reports and air pollution modelling
– Negotiated a special deal for reduced cost and multi-farm adverts
– Provided fact sheets and articles for the specialist press