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Paper presented at the 16th Annual JSR Technical Conference

 
Preparing for IPPC
Phil Huxtable, Technical Director, JSR Arable Farms

Commonly asked questions – and answers!

Philip Huxtable Philip Huxtable

Philip joined JSR Farms Ltd direct from Seale-Hayne Agricultural College in August 1976 as technical assistant to the rapidly expanding arable business.
       He was appointed as a Director to the JSR Board in October 1989, whilst continuing to develop his role as Technical Director to JSR Arable Farms. In addition to this role, Philip was appointed Property Director for the JSR Farming Group in September 2002, to create and develop the separate business area of JSR Property.
       Philip also advises on and formulates the JSR policy on environmental legislation issues, and has recently been instrumental in the setting up of RAPS (Recovered Agricultural Plastics Scheme) to cope with the impending Agricultural Waste Regulations.

a) What are the objectives of IPPC?

Started by EC legislative background - Council Directive 96/61/EC 1996 IPPC

Transposed in UK by separate PPC [Pollution Prevention & Control Regulations 2000] for England and Wales; Scotland; and Northern Ireland.

Implemented by EA; SEPA; DoENI respectively.

Common aims are...

  • To avoid/reduce emissions to air, water and land.
  • To minimise waste in the pig production cycle
  • To prevent pollution through implementation of BAT
  • No significant pollution is caused
  • Energy is used efficiently
  • Accidents are prevented and their consequences limited
  • To plan for safe decommissioning of the installation
b) Who is affected?

Does not affect outdoor pig units.

Indoor producers with installations either:
        > 750 sow places
        > 2000 finishing places over 30kgs

For a breeding/nursery/finisher unit (BNF) the 2000 production pig places over 30kgs becomes the limiting factor. This means that an IPPC permit will be needed before the 750 breeding sow place threshold is reached. The actual number of sows which are capable of filling the 2,000 pig finishing places will therefore depend upon sow productivity, growth rate and slaughter weight and is demonstrated below:

Clarification of what is an ”installation” still needed
    - All pigs on one site?
    - Separate breeding and finishing herds?
    - Separate sites but all one business e.g. JSR Wolds unit.
    - Not easy - discuss individual sites with EA.
c) When will IPPC take effect?

New and existing units with substantial change – immediately – where there is significant negative environmental or human impact.

For all existing units (as above) the “permit window” is from November 2006 to 31st January 2007, only a 3 month period – start preparations in good time!

d) What do the following abbreviations mean?

BAT: Best Available Technology – takes account of sector economics.
Will include a range of options and evolve over time.

BREF: Best available technical Reference documents.
Acts as the EC BAT reference note. Focuses on techniques to reduce emissions. All EC member states will take account of BREF.

SFIR: Standard Farming Installation Rules – from EA as agreed with NPA and NFU.
Covers the following areas – feed, water, waste minimisation, carcase disposal, fuel storage, pig housing, manure storage and spreading, energy use, accident prevention, odour, noise, vibration, records & monitoring, decommissioning plans.
To minimise emissions to air and land of dust, ammonia and odour
To minimise N in feed by matching protein needs to size of growing pig
Control conditions within animal housing

Edition 5 of SFIR now available from EA.

For example:

Slurry based systems – reduce slurry surface area, need for covered stores. If spread on own land need:-
  • manure management plan
  • Low emission spreading techniques e.g. injection
  • Incorporation within 24 hours.
Straw based system – BAT not yet designed.

Accident prevention by:
  • staff training
  • maintenance of structures and machinery
  • storage – bunding and spill/leakage containment
  • emergency plan
e) What do producers need to do?

Apply for permit between Nov 06 and 31st Jan 07 – if unit size exceeds thresholds.
Follow standard rules and any site specific conditions.
Move towards BAT.
Agree improvements and timescales with EA
Keep adequate records and monitor.
Improve environmental performance.

f) What advice is available to assist with filling in a permit?

As an R&D exercise, DEFRA assisted by ADAS have prepared permits for three “Template” farms (each a different type of pig farm) for submission to the EA in Spring 2005. One of these is JSR Southburn, selected for its closeness to the village and a SSSI (Southburn Beck). This is a very valuable exercise to JSR and we are learning the painful way what is involved!

Preparing a permit – what is needed?
  1. a site report to establish the “baseline condition” of the unit to include:- no of sows; types of housing, production system; herd size; feeding system; cleaning out arrangements; waste disposal; environment impact reduction measures e.g. tree belts.
  2. a farm map (incl spray stores)
  3. a unit plan – buildings/drains etc
  4. production methods are compatible with BAT
  5. emissions from unit compare with BAT
  6. list of “receptor sites” in 400 m vicinity of unit (e.g. school, housing, SSSI’s etc).
  7. documentary evidence -
      inspection & maintenance schedule
      evidence of staff training & qualifications
      raw material inventory fuel/oil/feed/chemicals
      feed regime and enzymes, and feeding method
      current water usage and audit
      current manure production & management - Manure Management Plan
      emergency plan – slurry tank failure or fire
      waste audit – plastics, carcasses etc
      how pollution is prevented from:
        feed delivery and preparation
        fuel and oils
        manure storage/handling/spreading
        odour/noise/vibration
      details of current energy usage and how this will be reduced – not needed if Climate Change Levy Agreement in place.
How any pollution emerging will be managed
How emissions will be monitored and samples recorded and managed
Assessment of the impact of site emissions upon the environment – any SSSI’s within 2km
Site decommissioning plan (no further risk when site eventually closes).

g) What is the cost of an IPPC permit?

Small units <10 x threshold, initial fee of £3,240 plus annual fee of £2,168 thereafter.
Large units >10 x threshold, initial fee of £3,240 plus annual fee of £2,718 thereafter.

Expect a period of 4 months between submitting an application and its determination.

Good news! – if you have an IPPC permit you will not be required to have a waste licence under the Agricultural Waste Regulations.

h) Where can I get more information?
1.Own records – knowledge of it/Assurance Schemes/Nutrient Management Plans
2. English Nature re SSSI’s
Defra publications
EA guidance notes
Defra/ADAS template farms
Training courses by PCS (Pork Chain Solutions)
MLC – Nigel Penlington based at Milton Keynes
BPEX Stotfold

Websites:

www.environment-agency.gov.uk
www.defra.gov.uk
www.npa-uk.net
www.bpex.org
www.stotfoldpigs.co.uk
www.thepigsite.com

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