INTENSIVE PIG INSTALLATIONS
SUBJECT TO PPC REGULATION UKPIR07
In order to facilitate effective PPC permitting for intensive pig
installations, sector specific application procedures and guidance have
been prepared by the Environment & Heritage Service (EHS), the
Scottish Environment Protection Agency (SEPA) and SNIFFER.
This study has been carried out at the end of the development phase of
the Application form and Standard Farming Installation Rules (SFIR) in
Scotland and Northern Ireland. The SFIR specify best
available techniques (BAT) for operational and management practices on
farms which PPC applicants have to comply with. SNIFFER
commissioned this research project to assess the implications of the
application of the PPC regime to intensive pig farms in Scotland and
Northern Ireland as well as the effectiveness of the application
Through this study, each of the regulatory authorities (SEPA in
Scotland and EHS in Northern Ireland) will gain a better understanding
of the PPC application process applied to the pig industry.
Pig farmers will also gain a better understanding of the implications
of the PPC regime. Both parties will be aware of where
difficulties lie and where further guidance is required to assist and
refine the application process. Clearly, a well-designed
application process together with clear guidance (including worked
examples) will help facilitate a cost effective application process,
providing all the information required in a consistent manner without
leading to any reduction in environmental benefits.
As part of this project a summary of information sources has been
prepared that an operator may draw upon to enable them to complete
their permit application form. This draws on relevant sources
of information produced by EHS and other bodies in Northern Ireland,
SEPA and SNIFFER. The list of documents relates to those that
were publicly available at the time this study was carried out and
identifies web sites (where available) to obtain the current version of
the document. As the application window for this sector approaches
further useful documentation may be issued.
Two intensive pig installations (one in Scotland and one in Northern
Ireland) were chosen as example sites to apply for a PPC
permit. An outline guide was prepared to assist the
applicants prepare the supplementary document required to elaborate
answers required on their application form. The draft permit
applications were then reviewed and the farmers assisted with
completing the application. The completed applications
provide example answers that could be applied elsewhere.
Through assisting the host farms complete their application areas where
operators may have difficulty in completing their applications have
been identified. Assistance was provided in the following
Geological and hydrogeological data along with soil
classifications in terms of leaching potential. This general
area appeared to be problematic.
The location of protected sites, both UK and European local
to the installations required ascertaining (the location of protected
sites in NI can be found on the EHS web site).
Conducting the site investigation (specifically identifying
all aspects that need to be considered in the application process) and
highlighting areas for remedial action.
Interpretation on the requirements for the protection of
fuel and liquid co-product tanks. In particular, it was
apparent that the need for some form of simple bunding around, or
catchment container underneath Intermediate Bulk Containers (IBCs) was
not well understood.
Guidance on the handling, storage and disposal of waste.
General guidance on the importance of document control,
record keeping and developing forms to ensure compliance is
demonstrated in terms of due diligence. Much of the
information and records required are already kept for other purposes,
and the host farmers expressed the view that it would be helpful if the
guidance explained that duplication is not expected and that the burden
of requirement is not as onerous as might appear at first sight.
Guidance on List 1 and List 2 (Schedule II) substances.
Clarification on issues related to Climate Change Levy
Development of accident scenarios.
Evaluation of the proposed emissions to the environment.
From the limited number of farmers who assisted with this study the
general areas of concern with the application process or where the
farmers think that it will be difficult to apply the SFIRs identified
the following points:
One site was concerned that a cover for the slurry tower
would be imposed at a capital cost when there had been no odour issues
with regards to the installation.
One site was concerned that whilst a lot of effort was
being put in to maintain ammonia and dust emissions at low levels, they
could be required to improve on this even though in their opinion there
is little scope for further improvement.
There was a general concern that there is too much
supporting information in addition to the SFIR and that the wording is
too complicated, not in a terminology used by farmers, and that more
plain English could be used.
There was concern that the agencies might apply the
legislation, and in particular the monitoring of emissions and
parameters associated with management plans (e.g. water audits), in a
heavy-handed manner resulting in unrealistic and impractical
The cost of permitting and the annual subsistence fee are
contentious matters for pig producers, in addition to which many are
now realising that these could be insignificant compared with possible
costs of compliance with improvement conditions, etc.
The practicalities of possibly having to treat storm water
is of concern due to the likely costs. The SFIRs should set
measurable criterion for the farmer/regulator to assess whether such
water requires treatment before discharge to water.
Key words: Permit, application, intensive, regulation, PPC, BAT, SFIR.
The two outputs from this project are each available separately in
electronic format at £20.00 + VAT. Hard copy
available at the following prices:
Main Report (Review of Application Process) £25.00
Example Permit Application: Scottish Farm £35.00