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This view is based on a visit by the Agency today to John Godfrey’s, at his request, to check whether his application – which will be the first of seven – is satisfactory. He invited me to listen in.

It is also based on feedback from Nigel Penlington of BPEX, who tells me some contract finishers have done little more than submit the model application, with appropriate parts crossed out and amended.

If you are stuck on some aspect of the application, or like John Godfrey you would like to run a completed application form past the Agency before actually submitting it, all you have to do is ring your local office and request a visit.

IPPC for pigs and poultry is as new to the Agency as it is to you, and its officers will welcome the chance to meet you and learn about any issues.

I noted that John Godfrey’s application was satisfactory in every respect. I gained the impression that it might in some parts have been more polished than is required by the Agency.

POINTS ARISING

As the forms are to be checked by real people it seems the odd marginal note by an applicant, to make some particular point clear, will be acceptable.

In section B2.3 "Emissions and Monitoring" all the "Yes" boxes were ticked even if they were not relevant, because there isn’t a “Not applicable“ option.

So “Footbaths are managed so that they do not overflow“ was ticked “Yes“ even though the Godfrey units have no footbaths, being shower-in-and-out.

The Environment Agency officers were not clear that ticking every box is the best solution as this will mean irrelevant conditions being included in the permit ie. “Footbaths must be managed so that they do not overflow“. They are to take advice and will report back.

For the geology data required with his application, John Godfrey used the Soil Survey of England and Wales 1978, and this was deemed satisfactory.

The application indicates a unit's records should be kept on site. However, the Lincoln officers who visited John Godfrey did not think it unreasonable that records be kept centrally - in this case several miles away at John's main offices.

EXPENSIVE

Whilst pleased that his first application was acceptable to the Agency, John remains firmly of the view that the whole IPPC process is unwieldy and extremely costly.

He is particularly concerned that it will put him and other applicants at a competitive disadvantage with non-IPPC units - including all outdoor breeding units, which are exempt.

It should also be noted that producers who submit acceptable permit applications are far from being home and dry. The sting will come – if there is to be a sting – in the conditions that the Agency attaches to each permit.

For instance, in common with most IPPC applicants, John Godfrey has a number of uncovered slurry stores. If the Agency wants these covered before they have reached the end of their natural life, the cost implications do not bear thinking about.

DOWNSIZING

But for those pig-keepers who are downsizing in order to slip in under the IPPC threshold there is some good news. A sound reason for reducing stocking density is to reduce disease, particularly PMWS.

Clearly you might not want to decommission drinkers or feeders just to prove you have reduced stocking density, as this could be counter productive.

So how, under these circumstances, would you convince the Agency that you have reduced stocking density to below 2,000 pigs? Nigel Penlington tells me the health argument is proving acceptable to the Agency.

Of course, if you go this route you must genuinely reduce the number of pigs to below 2,000, not just now, but going forward. The Agency may want to check your records and may even want to count the pigs - not unreasonable in the circumstances.

INSPECTIONS

The fault is no doubt mine but I couldn't get a clear picture on frequency of inspections. Inspections will be risk-based. However, as John points out, the larger an organisation the more likely it is to have a non-compliance, however well run. And once a non-compliance is recorded, the risk-visit cycle becomes self-perpetuating.

ThePigSite News Desk