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A multidisciplinary approach to environmental permitting

Published on May 12, 2021

If you undertake an industrial or commercial activity that could result in emissions to the air, water or land; increase flood risk; adversely affect land drainage, or have another adverse effect on the surrounding environment, you may require an environmental permit[i] from the appropriate country’s regulatory authority[ii] or your local council. If it is determined that you do need a permit, the conditions outlined within it must be met, so ongoing routine compliance checks are necessary. Any monitoring required can be supported by reporting to ensure that you are consistently and confidently meeting the conditions and, where possible, going beyond these to reduce your impacts on the natural environment. Furthermore, if the activity you are undertaking changes or is modified, it is likely that you will need to consider whether you require a permit variation. Or, if you are selling a site or activity, it may be necessary to transfer your permit to the new operator. Finally, if your operations cease or if you can demonstrate an environmental permit is no longer necessary for your operations, you may wish to surrender your permit. The whole cycle can begin again if the site use changes.

The environmental permitting cycle can be complex, time-consuming and costly. Employing the right company to manage the full life cycle of your environmental permits is likely to save you a lot of hassle, time and money. A company such as RSK can consider whether you are meeting the conditions in your permit, if it might be necessary to vary it or whether it is possible to surrender it, as the company will be constantly monitoring your activity and can inform you of any developments to the permitting status or new or amended legislative requirements.

If your activity requires conditions for more than one type of discharge; for example, air, noise and waste, employing a multidisciplinary consultancy could hold further advantages. Instead of engaging multiple companies to manage compliance with the various types of conditions, a multidisciplinary body can simultaneously monitor and report on all conditions and work to ensure one element is not detrimentally affecting another.

A multidisciplinary approach to environmental permitting

From noise to waste, air to ground, in whatever sector you operate, whatever you need monitoring and whatever conditions you need to meet, RSK’s multidisciplinary teams can assist. For example:

Waste

When a business uses, stores, recycles or disposes of waste in a manner that could lead to harm to the environment, more often than not, an environmental permit will be required. Ensuring that a business’s environmental permit is suitable for their activities is key to ensuring that they can operate effectively and with the minimum impact to the environment.

“While environmental permits can be costly and time consuming to prepare and are determined by the regulator, it is important to get them right to avoid all sorts of issues in the future,” comments RSK Senior Waste Management Consultant Andrew Sowerby.

RSK can provide a full service for both waste facilities and installations and will ensure that any required permit applications are completed to a high standard. We will provide support to help businesses remain compliant with both the permits themselves and other aspects of waste legislation.

Air quality

If you are required to apply for an environmental permit or need to vary an existing permit’s conditions, consideration needs to be given to whether an air-emissions risk assessment will need to be undertaken. This involves the assessment of the potential impacts your facility may have on local air quality, vegetation and ecosystems. Cumulative impacts may need to be assessed if any sites with significant air-pollution potential operate in the vicinity of your development.

RSK’s air quality team can support you in preparing such assessments. “These typically involve the preparation of a detailed air-emissions inventory, a predictive assessment of air quality impacts using dispersion models and the identification of emission control opportunities using best available technique (BAT) methods in order to ensure that your plant meets the air quality standards and Environmental Assessment Levels,” says RSK Air Quality Director Srinivas Srimath. “RSK has a proven track record in assessing air, odour and dust impacts to support our clients who operate in a wide variety of sectors: energy, intensive farming and waste handling, to name a few.”

Ground conditions

Operating under an environmental permit requires an appraisal and the investigation of ground (soil) and groundwater conditions before, during and after the activity that is being permitted is carried out, i.e., for the lifetime of the permit. “The extent and scope of any investigation necessary depends on the environmental sensitivity of the site and the nature and distribution of the activities being licensed,” says Associate Director Mike Owens. “RSK has developed a strong track record of helping its clients by undertaking the necessary risk assessment process to ensure the site investigation is designed to be fit for purpose. This includes providing an independent review of the pollution prevention and control measures in place to avoid impacts to soil and groundwater.”

RSK is experienced in providing ground investigations tailored to site characteristics and can help its clients demonstrate to the regulator that site conditions will be or have been maintained. Where contamination has occurred, RSK can design and undertake a detailed quantitative risk assessment or design and manage appropriate remedial actions.

Noise

“Although not visible, noise should be a key consideration in any development and may require an environmental permit,” comments RSK Acoustics Director Dan Clare. “RSK’s acoustics, noise and vibration team works closely with the other RSK business units to ensure conditions are met and impacts and effects are minimised.”

RSK is experienced in undertaking environmental acoustic noise assessments for permit applications and can provide local authority liaison, basic noise assessments, noise mapping, detailed atmospheric noise modelling, control of atmospheric noise propagation, ground-vibration propagation analysis, the prediction and specification of vibration mitigation measures and whole-building vibration isolation services.

Water

You may need an environmental permit if you “discharge liquid effluent or waste water [poisonous, noxious or polluting matter, waste matter, or trade or sewage effluent]: into surface waters, for example, rivers, streams, estuaries, lakes, canals or coastal waters – known as ‘water discharge activities’ [and/or] into or on the ground.” (UK government environmental permit guidance on discharges to surface water and groundwater.)

Water Research Centre Ltd (WRc), an RSK business, provides environmental modelling services to assist water companies and industrial clients to understand the impacts of their assets and operations on water quality. These can be from effluent discharges from treatment plants to intermittent wet-weather discharges from combined sewer overflows, storm tanks or pumping stations, whether these are located inland or in the coastal environment.

“WRc uses the Environment Agency’s SIMCAT-SAGIS model for water quality permitting and its own in-house SIMPOL integrated catchment model to investigate spill frequency, and quality assessment to support the Water Industry National Environment Programme (WINEP), the Storm Overflow Assessment Framework (SOAF) and Urban Pollution Management (UPM) investigations,” says Principal Consultant Dr Karen Murrell. “We also support the regulators with water-quality planning, using water-quality models to optimise permits at different scales: individual discharges or those at a river catchment or river basin scale. In addition, we provide training in the use of permitting models and the UPM procedure.”

Associate Director Robin Overton added, “For new developments, forward-thinking is required. While planning permission will allow you to build a new facility, only an environmental permit (if required) will allow you to operate it, and there are often advantages in considering both planning and permitting requirements simultaneously. An environmental permit can be considered to be a licence to operate.”

Anyone who could potentially require an environmental permit should consider both the full cycle (obtaining a permit, monitoring, variations, transfers and surrendering permits) and the full range of different discharges (noise, air, waste…) simultaneously. Using the services of a multidisciplinary company is often the easiest and most cost-effective way to do this.

For more information, please contact Robin Overton, at roverton@rsk.co.uk or on +44 (0)7917 187806.

 

 

[i] In England and Wales this can be termed an environmental permit under the Environmental Permitting Regulations. In Scotland and Northern Ireland, it can be a PPC permit under the applicable Pollution Prevention & Control Regulations. The term permit here also covers Waste Management Licences.

[ii] In England this is the EA (Environment Agency), in Wales the NRW (National Resources Wales), in Scotland SEPA (Scottish Environment Protection Agency) and in Northern Ireland the NIEA (Northern Ireland Environment Agency).

 

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ARTICLE AUTHOR

Robin Overton

Associate Director, RSK

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Robin is an associate director at RSK and directs environmental permitting projects, environmental engineering studies and resource efficiency projects throughout the UK. He is also a Chartered Chemical Engineer with an MSc in integrated pollution management and is a specialist with over 30 years’ experience in environmental engineering, permitting and compliance issues.

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