«How to comply with your environmental permit for intensive farming Introduction and chapters Version 2 January 2010 EPR Intensive Farming Contents ...»
EPR 6.09 Sector Guidance Note
How to comply
with your environmental permit for
Introduction and chapters
EPR Intensive Farming Contents Version 2
How to comply January 2010
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Email: firstname.lastname@example.org www.environment-agency.gov.uk © Environment Agency GEHO0110BRSB-E-E First published 2000 This version January 2010 All rights reserved. This document may be reproduced with prior permission of the Environment Agency.
This is an uncontrolled document. To ensure you are using the latest version please check on the Environment Agency website www.environment-agency.gov.uk
Record of changes:
Standard Farming Installation Rules and Guidance Version Date Change 1 1 August 2000 Initial version for use available on the website only, little changed from consultation version 2 24 November 2000 Revisions take into account the consultation comments and also restyling for publication 3 30 June 2001 Changed following comments received from industry 4 20 June 2005 Changed following comments from industry, experience from application, and to take account of Intensive Livestock BREF publication Intensive Farming – How to comply Version Date Change 1 April 2006 Fixed Permit Conditions used as conditions where possible with rules and guidance from version 4 of the Standard Farming Installation Rules. Additional guidance added for existing installations.
2 January 2010 Incorporating changes for the purposes of the Environmental Permitting Regulations Page 2 EPR Intensive Farming Contents Version 2 How to comply January 2010 Contents Introduction 4
1. Management 7
1.1 General management
Appendices Appendix 1 Protocol for sampling slurry and solid manure for analysis Appendix 2 Minimising emissions from new pig housing - examples of housing designs from the BREF Appendix 3 Minimising emissions from new poultry housing - examples of housing designs from the BREF Appendix 4 Odour management at intensive livestock installations Appendix 5 Noise management at intensive livestock installations Appendix 6 How to produce a manure management plan Appendix 7 Undertaking a housing review Appendix 8 Undertaking a drainage review Appendix 9 Producing a proposal for covering slurry stores Appendix 10 Emission reduction plan Page 3 EPR Intensive Farming Introduction Version 2 How to comply January 2010 Introduction This sector guidance note is about preventing pollution. It describes the standards and measures we expect intensive pig and poultry farms to take in order to control the risk of pollution to air, land and water.
This note applies to Section 6.9 of Schedule 1 to the Environmental Permitting Regulations (EPR) Part A(1)(a) Rearing of poultry or pigs intensively in an installation with more than:
(i) 40,000 places for poultry;
(ii) 2,000 places for production pigs (over 30kg) and/or (iii) 750 places for sows.
Poultry includes chickens, layers, pullets, turkeys, ducks, guinea fowl and quail. Pigs reared outdoors are excluded, but housed free-range poultry (egg-laying and chickens reared for meat) are included.
Farms regulated under EPR require a bespoke permit to operate. The permit will cover all aspects of farm management, from feed delivery to manure management.
Animal welfare is not dealt with by EPR - you must comply with appropriate animal welfare standards in the design and operation of the farm. You should not compromise the health and welfare of your livestock in order to comply with your permit.
EPR implement the Integrated Pollution Prevention and Control (IPPC) Directive in England and Wales and came into force on 6th April 2008.
The IPPC Directive requires that the Best Available Techniques (BAT) are used. When making an application, the costs and benefits of a range of options should be compared to show that your proposals represent BAT. If you propose to use the measures which are expressed as BAT in this note, you will not need to compare options. You should justify any departures from the BAT on a site-specific basis. In some cases an options appraisal may still be required, for example where indicative BAT is not included or where you propose to use an alternative measure. The BAT Reference Document (BREF) for Intensive Rearing of Poultry and Pigs has been produced by the European IPPC Bureau. Appendices 2 and 3 of this note contain examples of housing designs from the BREF for reference.
For bespoke permits, we would expect all new plant and livestock housing to be designed and built to the required standards. Where regulatory controls are being applied to existing plant we expect plant to be upgraded to meet the standards where necessary, and we set improvement conditions with a timescale. This would occur for example where a farm currently below the threshold expands above the threshold and would have a mix of existing and new buildings. We have set a target date of 2020, by which time we intend that all permitted installations will be achieving equivalent standards of environmental protection.
Modern permits describe the objectives (or outcomes) that we require – what we want you to achieve – but they do not normally tell you how to achieve them. They give you a degree of flexibility. Each section of this guidance gives the typical permit condition with which you must comply and then provides guidance on how to comply. References to figures and tables in the permit conditions refer to the figures and tables you will find in your permit.
Where a condition requires you to take appropriate measures to secure a particular objective, we will expect you to use, at least, the measures described in this guidance which are appropriate for meeting the objective. You may have described the measures you propose in Page 4
EPR Intensive Farming Introduction Version 2How to comply January 2010 your application or in a relevant management plan but further measures will be necessary if the objectives are not met.
When applying for your bespoke permit the application form asks you to explain how you will comply with the standards in this guidance.
Unless otherwise specified, the measures described in this guidance reflect those of the previous version of How to Comply (version 1, April 2006) and the preceding Standard Farming Installation Rules. Previous separate guidance on odour, noise and manure management planning are now appendices to this document. The measures will be reviewed in the light of future BREF note revisions. In the meantime we will take account of advances in BAT when considering any changes to your process.
The conditions that are in your permit are presented in shaded boxes throughout this
document, for example:
2.3.4 The operator shall maintain and implement a system to record the number of animal places and animal movements.
These conditions are followed by the standards and measures that you should take to comply with the condition. Links to further information are included where relevant.
You should only need to refer to this note for guidance on how to meet your permit conditions.
You do not need to use ‘Getting the basics right – how to comply with your environmental permit’ which includes guidance for all sectors regulated under EPR. We have incorporated the relevant information from ‘Getting the basics right’ into this document. You may need to consult guidance documents applicable to all EPR sectors, known as Horizontal (H) guidance, that give in depth information for particular topics, for example, H1 Environmental risk assessment and H4 Odour. The References section of this document lists these documents and where you can find them.
Key issues We want you to operate a profitable farm business. As part of this we expect you to monitor and manage environmental impacts as part of your everyday farm operations.
The key issues in the pig and poultry sector are:
Ammonia Ammonia is a gas that is directly emitted from livestock and from manure, litter and slurry. It can directly damage vegetation and it contributes to eutrophication and acidification of sensitive habitats. We expect you to minimise impacts on sensitive receptors.
Nutrients in manure/litter/slurry The key nutrients are nitrogen and phosphorus. A manure management plan will address soil nutrient status, crop uptake and nutrient requirements.
Effluent discharges These include discharges from roofs where fans vent to the roof and contaminated run-off from yards and housing. These can pollute surface water and groundwater.
Dust Dust can be a source of nuisance, odour and air pollution and may affect human health. It originates from bedding, feed and the animals themselves.
EPR Intensive Farming Introduction Version 2How to comply January 2010 Odour and noise Odour and noise can affect people living near your installation and can be a source of nuisance.
Accidents Accidents and emergencies can happen on any installation which could result in polluting discharges e.g. oil, pesticides, feed, affecting the environment.
Resource use We expect you to optimise the use of all resources on your farm. You will use a range of
resources and raw materials as part of your operation which include:
• Energy - operating more efficiently by reducing the energy used will reduce emissions of the greenhouse gas carbon dioxide per unit of output averaged over several years.
• Water – you should optimise water use which will also reduce waste water.
• Raw materials including biocides, pesticides, veterinary medicines, agricultural fuel oils and bedding – inappropriate storage and use can lead to environmental pollution. You should aim to use materials that have a reduced environmental impact.
• Feed – diets should be targeted to the livestock stage so nitrogen and phosphorus excretion is minimised. You should discuss the formulation of the diet with a nutritional advisor or supplier to ensure that the minimum dietary requirements of the animals are being met.
Priority areas for improvement for existing plant will be:
• safe storage of oils and materials
• integrity of buildings
• management of drainage systems
• management of manure and slurry systems Page 6
EPR Intensive Farming Chapter 1 - management Version 2How to comply January 2010
1.1 General management 1.1.1 The activities shall be managed and operated:
(a) in accordance with a management system, which identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformances and closure and those drawn to the attention of the operator as a result of complaints; and (b) by sufficient persons who are competent in respect of the responsibilities to be undertaken by them in connection with the operation of the activities.
1.1.2 Records demonstrating compliance with condition 1.1.1 shall be maintained.
1.1.3 Any person having duties that are or may be affected by the matters set out in the permit shall have convenient access to a copy of it kept at or near the place where those duties are carried out.
This condition means that you must: identify the risks that your activities pose to the
environment and take all reasonable actions to prevent or minimise those risks. In particular:
• you must design, operate and maintain all equipment whose failure may lead to pollution so that it continues to operate effectively;
• you must have identified potential accidents, put in place any necessary measures to minimise the chances of them happening and have plans in place to minimise the effects if the worst occurs;
• you must ensure that you have enough staff and that they are adequately trained in those aspects which could lead to pollution, including dealing with accidents and your responsibilities under your permit;
• have all necessary written operating instructions to ensure that staff know how to operate the plant safely under normal and abnormal situations.
You need to be able to demonstrate that you are doing this, that is, your control of your operations must be auditable. That means that your plans must be written down and you
must keep good records. In particular you must have:
• a maintenance checklist and maintenance records;
• an accident management plan;
• a list of the skills and training your staff need and a training record covering each staff member;
• any necessary operating instructions;
• a way of recording any complaints, pollution incidents or breaches of your permit and the actions you have taken to deal with them.
All of the above are the basics of what we mean by your “management system”. More details on them are given in the paragraphs below.
To keep your management system up to date you should review its content and associated accident management plans, site closure plans etc. at least once every four years. You should also review it if there is a significant change to the activities such as a company takeover, major re-structure or expansion of the activities. You should review the relevant parts Page 7
EPR Intensive Farming Chapter 1 - management Version 2How to comply January 2010 following an accident or if you find a non compliance, in an audit for example, in order to find the root cause. We too will be looking to identify the management system failure in these cases.
You also should regularly audit your own performance against your management system.
A basic management system described above may be sufficient for a farming installation, rather than an independently certified environmental management system (EMS).
www.envirowise.gov.uk is a useful source of help. Registration to ISO 14001 or EMAS, while valuable in themselves, do not guarantee permit compliance.