In this step we look at strategy. Strategy should be seen a method or plan chosen to achieve the desired goals and objectives that have been set by either national level or your own organisation. It will contain all kinds of actions that will contribute to these achievements. The issues addressed in this section are not limited and more issues could be added
The way permit conditions are set is by referencing the BAT conclusions, national guidelines, or by following national legislation. However the competent authority has the power to deviate from BAT conclusions as long as the performance levels i.e. the BAT AELs are met Derogations (setting less stricter ELV’s than BAT AEL) are open to appeal in court and competent authorities should be able to defend this. The submitted EIA can also play an important role when defining the permit conditions.
Reviewing existing permits:
According to article 21 of the IED the competent authority has to reconsider or review all permit conditions, and where necessary to update these permit conditions. When reconsidering permit conditions, the competent authority shall use any information resulting from monitoring or inspections. The IED also sets a timeframe of 4 years after the publication of BAT conclusions. See fact sheet 03 reviewing existing permits for answers to questions about reviewing of permits.
Objectives or targets for certain companies or industrial sectors
These objectives and targets that need to be reached are laid down in national legislation or in regional plans (e.g. air quality plan, action plans for noise reduction). Typical objectives or targets are set for air quality, risk reduction, odour, storm water runoff, waste management, reduction of greenhouse gases and energy efficiency. These objectives or targets should be translated in strategies within the permitting procedure.
Some examples are:
- The special requirements from legislation;
- The use of the EIA;
- According to the annual licensing plan;
- Control plan Air Quality;
- Industrial plans;
- Special guidelines that have to be followed. Deviation is possible in some circumstances;
- Regional programs for improving Air quality. There is an annual permitting plan which set priorities.
Encouraging and facilitating eco-innovations
Eco-innovations in terms of development and implementation of completely new processes and techniques leading to significantly improved monitoring, control or reduction of waste or emissions are key to achieving environmental goals and ambitions of Member States. Authorities can within the framework of IED permitting develop strategies and take various (organisational) measures aimed at proactively encouraging and facilitating operators who want to carry through eco-innovations.
Relationship permitting and inspection
Establishing and encouraging a good level of communication, information exchange and relationship between permit writers and inspectors/enforcers is very important. Not only the quality of the permits will benefit from this, also work can be done more effective and more efficient. There are a number of opportunities the inspector can have a positive involvement in the permitting procedure.
Transparency and visibility
Public visibility of the application, draft report and permit, submissions, objections and final report and permit. The permit procedure must be fully transparent and allow for public participation. This requirement is stated explicitly in the Industrial Emissions Directive and comes from the Aarhus Convention.
Internal and external communication
- Some good practices for internal and external communication are:
- Communication plan that ensures the involvement of various stakeholders in the process;
- Protocols that describes how letters are formally stored and how communication through internet can take place;
- A customer charter, which is published on the website of the competent authority and includes all applicable documents, correspondence and decisions by the competent authority;
- An annual internal communication plan, that includes: media relations, website and intranet, publications, internal communications, internal newsletters, exhibitions, environmental surveys, education etc);
- A national web based communication system for all communication between competent authority and applicants.