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Implementing legislation for Integrated Permitting

Monika Pribylova 1 October 2013 Air Quality Governance in the ENPI East Countries1In EU, there are countries which have: no implementing legislation but many more or less compulsory guidelines,one ordinance or regulation covering all necessary forms and instructions for the implementation,Several regulations or decrees with individual forms and instructions2Scope of the implementing legislationApplication form and instructions how to fill it inScope of the statement from concerned authorities Permit formAny compulsory methodology e.g. the content of BAT guidanceInstructions on setting up and organizing the BAT support body or system of information exchange on BAT

shall be defined in the environmental permitting law. In minimum the implementing legislation shall cover the following:

3Application form for integrated permit content 1/3Data on the company Environmental management systemData related to the installation and its location List of raw materials, secondary raw materials and other substances and energy consumed or producedDescription of emissions from the installation into all media and establishment of significant consequences of emissions on the environment and human health

4Application form for integrated permit content 2/3Description of the environment at the installation siteDescription of measures and equipment used for control of the installation and emissionsDetailed analysis of the installation in relation to BATList of measures after shutdown of the installation for avoiding all pollution or human health threats and remediation of the site

5Application form for integrated permit content 3/3J. Identifying participants in the process if the installation would have transboundary effects K. Statement of the operator with signatureL. Abbreviations and symbolsAnnexesProposal of integrated permit conditions

6Application form -proposal of permit conditionsThe content corresponds to the integrated permit content. For existing installation it should among others contain improvement program for compliance with BAT guidance.It represents the wish of the operator how the binding conditions in the permit should look like.This can be accepted by the regulator, or it becomes a base for negotiation.

7Integrated permit templateis based on the recommendations for the environmental permitting law addresses all of the requirements of the Industrial Emissions Directive 2010/75/EUall environmental media are addressed along with emissions and environmental monitoringcontains examples of conditions that could be set for an installation.

8Integrated permit template - contentDescription of the installation and connected activities and its locationOperating conditions incl. ELVs and other requirements to protect environment, reporting and improvement programExpiring of existing permitsJustificationInformation about appeal

Justification settlement of comments from participants of the procedure

9Operating conditions scope 1/3Emission limits for air and water protection and monitoring

10Operating conditions scope 2/3Emissions to land and related monitoringSite and RoadsPrevention of accidents and minimisation of their effectsManagement (e.g. operational instructions)Incidents and ComplaintsEfficient use of raw and supplementary materials and waterEnergy efficiencyWaste storage, handling, recovery or disposal11Operating conditions scope 3/3Noise and VibrationClosure and DecommissioningReporting on assessment of the compliance with permit conditionsOn site monitoringImprovement program12RecommendationsFirstly set up scope of the permit conditions.Design the application form, which will give you relevant information for making decision about permit conditions.It is useful to test both the application and the permit.Well structured application with relevant information is preconditions for smooth and efficient permitting procedure.

13Dkuji za pozornost time for lunch

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