The Environment Agency issued a new policy and guidance on protection of land quality and preparation of site reports under the Integrated Pollution Prevention & Control (IPPC) regime in August 2003 (www.environment-agency.gov.uk/business) The aim of the changes is to place more emphasis on pollution prevention measures within the PPC permit rather than site investigation at the time of application. It also hoped that the change will speed up processing of permit applications by the EA.

The site report accompanying the permit application (now referred to as the Application Site Report) should normally comprise the results of a desk study and site reconnaissance only. This is similar to a Phase 1a site report in the EA’s earlier terminology. Completion of intrusive investigations at this stage is NOT required except in special cases, e.g. there is insufficient data on site geology to develop the site conceptual model.

There is also now a requirement for operators to prepare a Site Protection and Monitoring Programme (SPMP) detailing how pollution of land will be prevented during the life of the installation. This has to be submitted to the EA within 2 months of the permit being issued.

Intrusive investigations to obtain ‘reference data’ (i.e. a Phase 1b or 2 assessment) are only required for zones of the site where there is ‘a reasonable possibility of future pollution of the land’ from installation activities. The guidance states that such investigations will always be required for sites with bulk storage of liquid chemicals, inadequate preventative measures or a history of pollution incidents unless it can be shown that there is little likelihood of future pollution occurring. The investigations will form part of the SPMP and where required have to be submitted to the EA within 6 months of the permit being issued.

The EA has also issued templates for the Application Site Report, design and reporting of a Site Protection & Monitoring Programme.

These changes apply to all sites in England and Wales where PPC permits have yet to be issued. Policy and guidance in Scotland and Northern Ireland currently remain unchanged. There are clearly implications for AGS members to ensure that appropriate advice is being provided to site operators applying for permits and that the most up-to-date guidance is being used.

References

Technical Guidance Note by IPPC H7
Integrated Pollution Prevention and Control (IPPC) Guidance on the Protection of Land under the PPC Regime: Application Site Report and Site Protection and Monitoring Programme
H7 Reporting Template 1 – Template for an Application Site Report in PPC Applications
H7 Reporting Template 2 – Design of a Site Protection and Monitoring Programme for Installations Requiring Reference Data to be Collected
H7 Reporting Template 3 – Design of a Site Protection and Monitoring Programme for Installations that DO NOT Require Reference Data to be Collected
H7 Reporting Template 4 – First Phase Reporting of the Site Protection and Monitoring Programme for Installations where Reference Data is Required
H7 Reporting Template 5 – First Phase Reporting of the Site Protection and Monitoring Programme for Installations where Reference Data is NOT Required

These can all be downloaded at www.environment-agency.gov.uk/business