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«How to comply with your environmental permit for intensive farming Introduction and chapters Version 2 January 2010 EPR Intensive Farming Contents ...»

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Energy supply techniques You should demonstrate that you have considered alternative, more efficient forms of generating electricity and heat where a cost/benefit appraisal shows them to be appropriate.

You should use the methodology provided in H2 for your cost/benefit appraisal. The following

techniques should be considered where practicable:

• use of Combined Heat and Power (CHP);

• using renewable energy sources;

• generation of energy by co-incineration of your waste;

• joint schemes with other local operators which may make CHP more attractive;

• use of less polluting fuels, such as biomass.

Energy efficiency review There are a number of audit guides and packages which will help you to produce an energy review (see further information). You should consider the following techniques in your energy


• insulating buildings;

• ensure equipment is working to optimum efficiency e.g. ventilation;

• applying low energy lighting;

• selection and control of heating systems.

Where can I get further information?

• H2 Energy Efficiency;

• Saving Money by Reducing Waste. Waste minimisation manual: a practical guide for farmers and growers, Defra 2006.

1.4 Efficient use of raw materials

1.4.1 The operator shall:

(a) take appropriate measures to ensure that raw materials and water are used efficiently in the activities;

(b) maintain records of raw materials and water used in the activities;

(c) review and record at least every 4 years whether there are suitable alternative materials that could reduce environmental impact or opportunities to improve the efficiency of raw material and water use; and (d) take any further appropriate measures identified by a review.

Raw material selection Selecting raw materials and the process techniques presents an opportunity to control emissions at source by reducing usage or substituting materials that are less harmful or which can be more readily abated.

You should make a list of the main materials used which have potential for significant

environmental impact, including:

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EPR Intensive Farming Chapter 1 - management Version 2

How to comply January 2010

• quantities used;

• chemical composition, where relevant;

• fate of the material (i.e. approximate percentages to air, land, water and products);

• environmental impact potential, where known (e.g. toxicity, bioaccumulation potential, degradability);

• any practicable alternative materials that may have a lower environmental impact;

• justification for the continued use of any substance for which there is a less hazardous alternative (e.g. on the basis of impact on product quality or costs vs. environmental benefits).

These records should be maintained in a format equivalent to that supplied in your permit application and should be made available to us on request.

The raw materials inventory should be included as an appendix to the accident management plan.

You should review this situation every four years and identify whether there are alternatives.

Minimising water use Review You should carry out a review of water use (a water efficiency audit) at least every four years.

The first audit shall take place within two years of the issue of your permit unless your application has included details of a satisfactory audit carried out in the two years prior to submission of the application. You may wish to identify livestock water consumption separately from other uses.

When reviewing water use you should:

• inspect water supply pipework systems regularly and repair any leaks as soon as practicable;

• produce a plan identifying all water supply and distribution pipework for water at the installation, including the location of water meters;

• establish water efficiency objectives, based on sector benchmarks (see Waterwise on the farm);

• identify constraints on reducing water use beyond a certain level, such as livestock water consumption;

• establish the water quality needs of each use, so that you can identify opportunities for recycling, for example rainwater harvesting;

• use this information to identify opportunities for reducing water use;

• prepare an action plan to reduce water use.

The timescale for implementing the improvements should be agreed with us.


You should apply the following general techniques in sequence to reduce emissions to water:

• Use water-efficient techniques at source wherever possible.

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EPR Intensive Farming Chapter 1 - management Version 2

How to comply January 2010

• Recycle water within the process from which it issues, by treating it first if necessary.

Where this is not practicable, recycle it to another part of the process that has a lower water quality requirement.

• If you cannot use uncontaminated roof and surface water in the process, keep it separate from other discharge streams, at least until after the contaminated streams have been treated in an effluent treatment system.

• Keep more contaminated water streams separate from less contaminated streams where there is scope for reuse – possibly after some form of treatment.

• Consider the use of treated final effluent, perhaps after mixing with fresh water.

• Directly measure and record fresh water consumption regularly, ideally every day, but at least monthly at every significant usage point.

• As part of your ongoing management, you should include general efficiency techniques

such as:

▪ Vacuuming, scraping or mopping in preference to hosing down.

▪ Reusing wash water (or recycled water) where practicable.

▪ Using trigger controls on all hoses, hand lances and washing equipment.

• Insulate exposed water pipes above ground, or install suitable systems to reduce the risk of freezing pipes.

• Install stop taps and drain valves in the water distribution system.

• Install covers on water tanks.

• Annually calibrate drinking water installations and meters.

Where can I get further information?

• Waterwise on the Farm, Environment Agency/NFU/LEAF guidance;

• Saving Money by Reducing Waste. Waste minimisation manual: a practical guide for farmers and growers, Defra 2006.

–  –  –

1.5 Avoidance, recovery and disposal of wastes produced by the activities 1.5.1 The operator shall:

(a) take appropriate measures to ensure that waste produced by the activities is avoided or reduced, or where waste is produced it is recovered wherever practicable or otherwise disposed of in a manner which minimises its impact on the environment;

(b) review and record at least every 4 years whether changes to those measures should be made; and (c) take any further appropriate measures identified by a review.

This condition is important because it requires you to demonstrate waste avoidance or reduction measures. It also requires that where waste is produced you do not automatically choose the cheapest waste disposal option but consider recovery options. It requires you to think about the impact on the environment of all the available options and select the option which is best for the environment.

You will be required to:

• consider if you can avoid producing a waste;

• consider reducing the amount of waste produced;

• characterise and quantify each waste stream arising from the installation;

• describe how each waste stream is to be recovered or disposed of.

If you propose any disposal:

• explain why recovery is technically and economically impossible; and

• describe the measures planned to avoid or reduce any impact on the environment.

• is the waste disposed of in accordance with relevant legislation so that the environmental impact is minimised?

You should carry out a waste minimisation review at least every four years. The first review shall take place within two years of the issue of your permit unless your application has included details of a satisfactory review carried out in the two years prior to submission of the application.

You should submit the methodology used for the review and an action plan for reducing the use of raw materials within two months of completion of the review.

The review should have a content equivalent to the Defra guide ‘Saving Money by Reducing Waste’.

Where can I get further information?

• Saving Money by Reducing Waste. Waste minimisation manual: a practical guide for farmers and growers, Defra 2006 Page 17

EPR Intensive Farming Chapter 2 – operations Version 2

How to comply January 2010

2. Operations In addition to the conditions set out below, there may be additional conditions in this section of your permit, for example, pre-operational conditions or waste acceptance. We expect few farms to have these conditions. The numbering of the conditions in this section of your permit may differ from that described below.

2.1 Permitted activities 2.1.1 The operator is authorised to carry out the activities specified in schedule 1 table S1.1 (the “activities”).

Regulations list many different activities but you are only permitted to carry out those listed in

your permit. However, you may carry out other activities on the site provided that:

• they do not need a permit under any legislation; or

• they are exempt from the requirement to have a permit, for example because they are carried out on a small scale; or

• you have a separate permit issued by the Environment Agency or by another regulator such as the local authority.

–  –  –

2.2.1 The activities shall not extend beyond the site, being the land shown edged in green on the site plan at schedule 2 to this permit.

Schedule 2 of your permit will contain a site plan. This will either be the site plan you submitted with your permit application or a plan produced by us. You must ensure that you don’t carry out the permitted activities beyond the site boundary. You must tell us if you wish to change your installation boundary and you will need to apply to vary your permit.

2.3 Operating techniques

2.3.1 (a) The activities shall, subject to the conditions of this permit, be operated using the techniques and in the manner described in the documentation specified in schedule 1 table S1.2, unless otherwise agreed in writing by the Agency.

(b) If notified by the Agency that the activities are giving rise to pollution, the operator shall submit to the Agency for approval within the period specified, a revision of any plan specified in schedule 1, table S1.2 or otherwise required under this permit, and shall implement the approved revised plan in place of the original from the date of approval, unless otherwise agreed in writing by the Agency.

Table S1.2 of Schedule 1 of your permit will refer to selected documents that you supplied with your application for a permit – for example your management plans or procedures.

We expect you to operate in accordance with these. However, if a pollution problem arises we may require you to revise your plans and procedures.

We expect you to use the operating techniques set out below.

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EPR Intensive Farming Chapter 2 – operations Version 2

How to comply January 2010 Selection and use of feed Technical standard: you must take appropriate measures to provide a diet which minimises the excretion of nitrogen and phosphorus.

Appropriate measures for pigs Nitrogen

• A minimum of two diets should be available for all pigs over the production cycle.

Consider the whole production cycle as this may include outdoor rearing.

• Sows ▪ for the majority of the period between weaning and farrowing, the diet for sows should be formulated to meet the nutritional requirements of the dry sow;

▪ for the antenatal period, during lactation, and for some time post weaning the diet should be formulated to meet the nutritional requirements of the lactating sow;

▪ the dry sow diet should have a lower level of crude protein than the lactating sow diet.

• Rearing and finishing pigs ▪ Where a two-diet system is used for rearing and finishing pigs between 25 and 90kg the change over should be made at around 50 to 60kg. The latter diet should have a lower crude protein level. Where higher numbers of diets are used the change should be appropriate to the lifestage.

▪ Where rearing and finishing pigs are routinely taken to weights over 115kg, a third diet shall be fed at 90kg and above with a further reduced protein level.


• Phosphorus levels in rations for pigs should be reduced over their rearing and production cycle.

• The addition of digestible phosphorus, or the use of enzymes such as phytase will ensure optimum performance and maintenance, whilst limiting the excretion of phosphorus.

Buildings and associated infrastructure

• All buildings and associated infrastructure i.e. feed storage bins, should be specifically designed to allow at least a two-stage feeding regime.

Appropriate measures for poultry Nitrogen

• Broilers and broiler breeders should be a fed a minimum of three diets.

• Commercial laying hens should be fed a minimum of three diets over the whole cycle.

• For replacement layer pullets and rearing of breeding stock, a minimum of two diets should be used between hatching and point of lay for optimum feed utilisation.

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