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EPA Online Application Process

To obtain an Industrial Emissions (IE), Integrated Pollution Control (IPC) or Waste licence or revised licence from the Environmental Protection Agency (EPA), applicants must now apply using the new online application form. Access to this online application form is via the Environmental Data Exchange Network (EDEN) online portal. The online application is supported by a number of template documents that need to be completed and uploaded into the online application form.

Notable changes to the application process include:

  • Applicants must now specifically address measures to be taken for minimising pollution over long distances or outside the territory of Ireland;
  • Applicants must provide details of past bankruptcy or other insolvency proceedings and a Financial Commitments Declaration must accompany the application;
  • Greater consideration has been given to substances of very high concern and substances carrying the Hazard Statement H400 to 413 (hazardous to the aquatic environment) and hazardous substances with damaging effects on sensitive plants and ecosystems in terms of BAT, emissions and waste generated;
  • Additional requirements regarding information the Best Available Techniques (BAT) applicable to the activity and on the main alternatives considered:
    • For Industrial Emissions (IE) licence applications, a description of the main alternatives studied must be included in the attachment against the reference document on Economic and Crossmedia Effects. This is also required for Waste and IPC licence applications where an Environmental Impact Assessment Report does not accompany the application;
    • For IE licence applications, BAT is described in BAT Conclusions (BATC) documents and these must be the reference for setting licence conditions. The EPA has provided some pre-populated template BATC documents to assist with BAT assessments. 
  • Applicants must provide details of solvent activities and consumption and details of how the site will comply with the specific requirements of the Solvents Regulations (Chapter V of the Industrial Emissions Directive) – e.g. Reduction Scheme, Limit Values, etc. Where a derogation from emission limits for fugitive emissions is being sought, the applicant must demonstrate to the satisfaction of the EPA that the fugitive limit value is not technically and economically feasible and that BAT are being used. The applicant must also propose measures/ limits to safeguard the protection of human health and the environment.
  • Applicants must provide specific information on large combustion plants (LCP) based on the requirements set out in Chapter IV and Annex VI of the Industrial Emissions Directive. The EPA provides a template which must be completed foreachlarge combustion plant (i.e. total rated thermal input of which is equal to or greater than 50MW, irrespective of the type of fuel used).
  • Similarly, applicants must provide specific information on waste incineration plants and waste coincineration plants based on the requirements set out in Chapter III and Annex V of the Industrial Emissions Directive. Again, a template must be completed foreachwaste incineration and co-incineration plant.
  • As always, applicants must ensure that the quality of any relevant receiving water is not impaired and that the relevant Environmental Quality Standards are not exceeded as a result of emissions to sewer. An assessment of ‘equivalent level of protection’ must demonstrate that the level of treatment of an installation’s effluent, on and off site, is collectively equivalent to BAT and environmental quality standards will be observed in the receiving water (i.e.,‘equivalent level of protection’). As such, the effect of treatment by the receiving WWTP may now be taken into account when setting emission limit values.

The new application process is not paperless as yet. The EPA will still require 1 signed hardcopy of the application; which is only submitted once the EPA has deemed the application to be complete.

Environet has many years’ experience in the preparation of licence applications across a range of sectors. We can assist through all stages of the application process, from initial discussions and licence scoping with the EPA, through to completion of application form and compilation of necessary assessments. Further information and guidance on the application process can be found here.

September 2018