IPPC is an otiose piece of legislation. It will impose a considerable strain on European pig producers, inevitably causing some to quit, whilst doing little to save the planet, because production will be transferred to less exacting parts of the world.

It is also nightmarish and could have come only from Brussels. It has taken a simple concept - 'let's get pig farmers to clean up their act' - and turned it into a complex edifice requiring the creation of a whole new, unproductive army of bureaucrats.

And it is unforgivably cavalier. It demands thousands of hours of producers' time, failing to recognise that though time may be infinite for the administrator class, it is an expensive finite resource for small businesses, most of which are unable to afford extra staff for non-productive tasks.

(It is hardly necessary to add that in livestock production it is generally impossible to pass on extra costs. Retailers can do it, but processors can't, nor can producers.)

And most of all, IPPC is tragic. How could such a laudable ambition - to make Europe a cleaner place for our children - have been translated into such an infamous tract of legislation?

Had IPPC been good law, producers might have responded almost enthusiastically to the challenge of making their pig units more environmentally acceptable. As it is the industry must make the most of a bad lot, because IPPC and it isn't going to go away.

The pig industry's aim now must be to minimise the pain of this directive without reducing its environmental effectiveness. This means persuading the Environment Agency to see its policing duties in a new light.

Producers should not be plunged into gloom by the shortcomings of IPPC. Some will doubtless take it in their stride, as will their counterparts on the continent. But the important point is that with a bit of thought and goodwill it could have been so much less bureaucratic, and as a result so much more effective.

As of today, unless the Environment Agency has a major rethink about the way it implements IPPC, the British pig industry, which has recently started to expand again after five years in the doldrums, will find it is critically short of pigs by the end of next year.

Nobody knows how many producers are caught by the IPPC net of 750 places or more for sows, or 2000 places or more for finishers.

But a ballpark figure would be 500 (outdoor pigs are exempt). Feedback to date suggests that committed breeder-feeders will be applying for a permit, no matter how many hoops they have to jump through on the way.

The problem comes when we look at finishers. A good number of these are bed-and-breakfasters and some have made it clear they are not prepared to pay a permit fee of £2,950-£6,900 for the privilege of finishing someone else's pigs, nor are they prepared to live with the IPPC bureaucracy.

In other words, they will radically downsize, or quit. The industry cannot afford to lose a large slice of its finishing capacity so it must work hard this year to reduce the burden of IPPC paperwork and the cost of a permit - even if ultimately it means going to Judicial Review.

So how much simpler will IPPC be, if the Environment Agency can be persuaded to change direction?

To answer this we need to look at what the legislation seeks to achieve, and how Brussels envisages it being implemented.

Its over-riding aim is to eliminate as much pollution as possible, in terms of emissions to the air, water and soil, with the cost being borne by the polluter. To achieve this, it wants pig producers to apply best practice in their farming, as laid down in periodically updated best practice guidelines.

And that, in a nutshell, is IPPC. What could be more sensible? What could be simpler? It wants waste to be handled sensibly and energy to be used efficiently.

The problems start when the IPPC directive tries to determine how best practice can be policed. It stipulates that a pig producer's IPPC permit must include a description of:

• The pig unit and its activities.
• The raw materials and energy used.
• The sources of emissions (ammonia, phosphates, dust, noise etc).
• The quantities of emissions to air, soil and water.
• The methods used to prevent or minimise emissions.
• The measures to monitor emissions.

It leaves member states free to decide exactly how this should be achieved, allowing each country to take into account local conditions, as long as it doesn't act in a way that would give its producers an unfair advantage over producers in other member countries.

You can see from the above that with a bit of goodwill on all sides, IPPC could be a straightforward and effective piece of legislation; something that our producers could embrace positively.

A suitably qualified and independent person would come onto your unit for two or three days and would compile a single report with the appropriate sub-headings. Areas for improvement would be noted, along with target dates, the report would be submitted to the Environment Agency, and the IPPC permit would be granted.

True, the suitably qualified person might come at a high price, but this system would be so much simpler that the permit charge of £2,950-£6,900 could be significantly reduced, to offset the cost

But the way the Environment Agency is tackling IPPC is far less simple. It requires producers who are applying for a permit to write and submit separate reports, plans and what-have-you, for each of the various headings.

It even proposed at one point that permit applicants submit ten copies of each report. You couldn't make this stuff up. It is difficult to calculate the number of man hours involved but suffice to say that anyone who hasn't started the process by the beginning of next year might not be done in time for the January 2007 deadline.

Of course, you could always bring in a specialist to handle the whole process for you, but if you do, be prepared for a bill of over £10,000, and for just one unit.

Now the Environment Agency might argue that a more simple method of implementing IPPC would not get past Brussels. The agency might point out that the IPPC directive insists on quite specific and detailed information about each unit.

For example… "The permit shall include emission limit values for pollutants likely to be emitted from the installation concerned in significant quantities, having regard to their nature and their potential to transfer pollution from one medium to another (water, air and land). If necessary, the permit shall include appropriate requirements ensuring protection of the soil and ground water and measures concerning the management of waste generated by the installation."

But the IPPC directive makes clear that it is up to each member state to consider the technical characteristics of a unit, its geographical location and the local environmental conditions.

The phrase "local environmental conditions" is important. To understand why, we need to take another look at the aims of IPPC.

As far as pig production is concerned the main aim is to ensure that the waste from pigs does not pollute the environment. It wants producers to feed pigs sensibly, to reduce pollutants in the slurry, and then to handle the waste sensibly so as not to apply more to the land than can be taken up by growing crops.

In its best practice guidelines it acknowledges that "A high density [of intensive pig farms] might suggest that the mineral supply available for the animal manure might exceed the requirements of the agricultural area for growing crops and maintaining grassland."

It goes on to note that the highest densities of pig production are in the Netherlands, Belgium and Denmark and that where there is a concentration of livestock production at a regional level it can cause…

• Acidification from ammonia, sulphur dioxide and nitrogen monoxide.

• Eutrophication (the process by which water becomes enriched in dissolved nutrients such as phosphates, stimulating the growth of aquatic plant life and usually resulting in depletion of dissolved oxygen) from nitrogen and phosphorous.

• Local disturbance from smells and noise.
• Diffuse pollution from spreading of heavy metals.

The Environment Agency should note that the British pig industry does not suffer from regional concentrations of pigs. Therefore it should implement IPPC in a proportionate way.

East Anglia is a pig area but most of the breeding herds are outdoors and not currently affected by IPPC. Furthermore it is primarily a highly productive arable area and there is more than enough arable acreage to take up the 'waste' created by pigs.

There may once have been a concentration problem in East Yorkshire, but no longer. And this region - as with East Anglia - is mainly arable and can easily cope with current levels of pig waste.

NPA's task this year will be to stress the importance, to the Environment Agency, of "local environmental conditions". We must lighten the load of the IPPC paperchase if we are to keep the British pig industry viable. And we must do so without lessening the drive towards more environmentally-responsible pig production.

It can be done but it won't be easy. It may be that the European Commission and/or Defra will have to help. Senior figures in both have privately expressed doubts about the way Environment Agency is handling IPPC.

A final point on this subject. The IPPC directive makes it clear that IPPC is living legislation insofar as it will continue to embrace advances in best-practice pig farming, and therefore permit holders will be constantly under review. So doesn't it make sense for the Environment Agency to start gently, see what can be achieved, and then, if necessary, firm up on the areas where sufficient improvement isn't being achieved? I think so.

Specific areas of concern