mjac founded 1928 walsall update 24 march 2014 air regulation [email protected] 01543...

MJACMJAC

Midland Joint Advisory Council for Environmental

Protection Founded 1928

Walsall Update 24 March 2014

Air Regulation

[email protected] 01543 308734

Technical Committee (Air Reg)

Committee Members:

Neil Wait [email protected]

Phil Kershaw [email protected]

Ian Rathbone [email protected]

Lynda Fawthrop [email protected]

Tony Higgins [email protected]

Gerg Jambor [email protected]

Pollution Prevention and Control

Process Guidance Note Review

20 December 2013 Defra published 13 revised PG notes, including 9 new simplified permits.

Petroleum and powder coating

PG 1/13 Storage, unloading and loading petrol at terminals

PG 1/14 Unloading petrol into storage & motor vehicle refuelling, at service stations (Includes model permit)

PG 6/31 Powder coating including sherardizing and vitreous enamelling dry (Includes new model permit)

PG 6/42 Bitumen processes (Includes new model permit)


Organic chemicalsPG 4/02 Polymerisation or co-polymerisation of pre-formulated resins or

gel coats containing unsaturated hydrocarbons (Includes new model permit)

Animal and Vegetable Processing

PG 6/05 Maggot breeding installations (Includes new model permit)

PG 6/12 Production of natural sausage casings, tripe, chitterlings and other green offal (Includes new model permit)

PG 6/19 Fish meal and fish oil processes and installations (Includes new model permit)

PG 6/21 Hide and skin processes


Animal and Vegetable Processing cont…

PG 6/24 Pet Food (Includes new model permit)

PG 6/26 Animal feed compounding (Includes new model permit)

PG 6/30 Mushroom substrate manufacturing processes and installations

PG 6/36 Tobacco processes (Includes new model permit)

Note: Revised fees for simplified permits.

New installations from now and existing from Jan 2015


New Simple Permit issues…

Numerous queries raised on Knowledge Hub, and to Defra by MJAC Technical Group, particularly regarding PG1/14 Petrol Stations.

For example, regarding maintenance:

There is no requirement to test or re-test the Stage I vapour recovery system in the model permit and yet the PG note refers to 3 yearly checks for correct functioning of the PVR valve? PVR valve functioning is covered by the generic condition 1 which requires there to be a functioning vapour return system in use. We no longer require the specifics on testing as the generic condition 1 requiring a functioning system covers this need.

So, none specific ! Enforcement issues !!


Defra Better Regulation Team

Presentation given by Defra to the Part A Forum in January.

Follow on from Red Tape Challenge. Some points raised:

Ambition for significant progress over next two years - reforms to guidance, data reporting, inspections and “vertical” reform of legislation.

By March 2014 the aim is to:

• Carry out a “zero-based” review to collect only the information that is essential and used;

• Streamline how that information is collected, starting with a pilot on waste.


Defra Better Regulation Team cont…

Proposals:

•Stop collecting information.•Reduce the number of transactions.•Businesses only notify important changes. •Exclude reporting of low risk activities, especially those which do not require

any active decision by the regulator.•Offer standard rules licences for more activities.•Allow reporting via accredited third parties.•Challenge ad hoc requests for information.•ICT solutions for simplifying transmission of information.


Defra Better Regulation Team cont…

626 environmental regulations reviewed area by area, e.g. water quality, biodiversity, land, etc.

Plans to improve 45%, scrap 22% and keep unchanged 33%.

Currently forecasting savings to business of >£1bn over 5 years. Guidance and data reforms may double that figure

Red Tape Challenge also identified reforms of EU legislation.

Prime Minister’s business-led Task Force on EU Regulation has made other suggestions.


Energy Efficiency Directive

Defra consultation on transposition closed Friday (21/3)

Current EA consult on changes to H2 Energy Efficiency Guidance until 11/4/14https://consult.environment-agency.gov.uk/portal/ho/ep/h2energyefficiency/h2_energy_efficiency?pointId=2831815

Article 14 (5-8) of the Energy Efficiency Directive (EED) places a requirement on operators of combustion and energy from waste plants greater than 20 MW thermal input to carry out a cost-benefit assessment (CBA) of opportunities for combined heat and power or recovery of waste heat from industrial processes.

The consultation documents comprise: • Guidance on who, what & how has to carry out a CBA.• An Excel spreadsheet template for operators• A description of how the template was devised


Environmental Permitting (England and Wales) (Amendment) Regulations 2014 (S.I. 2014/255)

Came into force on 11 February 2014

Key amendments:

•Removes requirement to ‘not grant’ waste permit if no planning permission

•Removes LA requirement to maintain EA public register.

However, before you dump! There could be some useful info for emergency planning & con land.


MJAC Risk Assessment Project with Defra

Technical Group competed draft Part B risk assessment – a single simplified risk rating for all Part B.

Completed testing with help from members – positive outcome with good correlation

Drafted user Guidance document & a Justification document regarding the changes made.

Submitted to Defra with view of approval & launch in April 2014


MJAC Risk Assessment Project with Defra Cont…

Now, all change at Defra….

Richard Vincent moved to nano technology and replaced by Nicola Leeds.

Nicola has a waste background, and is temporally covering both areas prior to a full swop over to permitting.

The department Director has also changed.

Also, new Committee procedure to approve any new guidance. Basis is nothing in addition; replacement to be 90% less than original; committee Chaired by George Osborne.


MJAC Risk Assessment Project with Defra Cont…

So, impact on risk method??!!

•Definitely needs to go to IPCLAG and Industry Forum for approval (no dated set for either)

•Avoid ‘new guidance ‘ committee

•Looking into launch on Defra website in April as ‘risk tool’ to get it out

•May need to be included in next fees & charges consult

•General direction sought from new head……


MJAC Permits Library

www.mjac.org.uk/permits-library.html

Aim to achieve a wide range of sectors and to promote best practise & consistency for members

Please submit your permits to [email protected]


Environmental Offences definitive guideline

Following a consultation the Sentencing Council is publishing its new definitive guideline on environmental offences, which has been issued in accordance with section 120 of the Coroners and Justice Act 2009.

This guideline applies to all offenders aged 18 and over and organisations sentenced on or after 1 July 2014

It includes permitting offences.

http://sentencingcouncil.judiciary.gov.uk/guidelines/forthcoming-guidelines.htm#Environmental_offences_definitive_guideline


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Pollution Prevention and ControlPollution Prevention and Control

mjac founded 1928 walsall update 24 march 2014 air regulation [email protected] 01543...

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