Environment Agency must try harder to reduce IPPC costs

UK - The Environment Agency claims it has cut IPPC charges to the bone. Pig and poultry producers don't believe it, says Digby Scott.
calendar icon 1 February 2007
clock icon 4 minute read
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National Pig Association
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There is a fundamental belief in the pig and poultry industry that the Agency is over-implementing the IPPC directive. It is clear the costs of complying with the Agency’s demands is excessive and will lead to uncompetitiveness, say NFU and NPA.

The Environment Agency on the other hand believes it has pared its regulatory role as far as it can within its statutory constraints. It believes it is applying a 'proportionate' approach. It points to its engagement with the industry’s representative bodies, the workshops it has held, and its streamlined application form and simplified advice and guidance.

But NFU and NPA are clear the IPPC regulations are being over-implemented. The degree of detail and enforcement are disproportionate to the risk and the actual incidences of pollution, and this has resulted in disproportionate charges, says the NFU. The fee for a permit application is £3,331. The subsistence fees are £2,229 or £2794, depending on the size of the IPPC ‘installation’.

The Environment Agency claims it has done ‘a considerable amount’ to reduce pig and poultry charges to around one third of what would otherwise be charged to other sectors of equivalent risk and effort. It says it is doing much of the work for farmers that other industrial applicants would be expected to do themselves, for example modelling the impact on Habitats Directive sites. (Farmers still have to pay for this work.)

The Agency estimates it will take 43 hours to determine each IPPC permit. The pig and poultry industry says it could lop at least 12 hours off this, which would result in a permit fee reduction of some £700. But the Agency claims it has already cut times and costs by a factor of three and cannot commit to a lower fee until it has assessed the majority of the applications.

As a result, NFU and the Agency have agreed that farmers must make their applications by January 31 with the current fee. But the Environment Agency is prepared to report back later in the year. It says if it has managed to do the work at lower cost it will make a ‘downward adjustment’ in the following year’s subsistence charges. The final cost will depend on the number, qualityand timescale of applications.

IPPC and farm assurance

An IPPC farm assurance bolt-on has been developed that would cost farmers about £450 a year. But - disappointingly - this will reduce the Environment Agency subsistence fee by only £600 because - assurance inspection notwithstanding - the Agency insists on carrying out an annual inspection itself.

And the £600 reduction will only be given, it says, to those who have been assessed to have satisfactory compliance with the IPPC module, allowing the Agency to reduce its inspection level. The pig and poultry industry believes this is gold-plating and once a baseline is established, good farms should not need more than an annual farm assurance visit.

NFU has told ministers that despite a review with the Environment Agency of IPPC costs, the industry’s view is that the Agency has not reduced its costs enough. Government ministers are intensley interested in this issue. They will be taking matters further.

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