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Integrated Permitting Initiative

Integrated Permitting Initiative. US EPA State-EPA Symposium on Environmental Innovation and Results January 24, 2006. Unique Collaboration Opportunity. UK and US Tim and Chris, EA Sector Specialists, attorneys, and permit writers

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Integrated Permitting Initiative

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  1. Integrated Permitting Initiative US EPA State-EPA Symposium on Environmental Innovation and Results January 24, 2006

  2. Unique Collaboration Opportunity • UK and US • Tim and Chris, EA Sector Specialists, attorneys, and permit writers • EPA-wide team of permitting and other experts (Regions 10, 5, OIA, NCEI) • EPA and States

  3. Overview of US Initiative –Phase I (2005-2006) • Phase I: Assess Potential for Transferability • National Network of EPA and State practitioners as well as senior leadership • Research and analysis • Anticipate July 2006 delivery • Strategic recommendations (to be based on analytical report findings)

  4. Phase II (2006-2007) • Explore testing opportunities • Identify potential applications of UK tools • Identify working partners and “connections” • States (State Innovation Grant Program and others) • Multinational, “leader” companies • Sectors (focus on UK/EPA targets) • EMS, Lean, US Performance Track

  5. Research and Analysis –General • IPPC/PPC • Legal Framework • Tools (H1, OPRA) • Sector Approach • Administrative Costs/Benefits (aggregate) • Environmental Results (aggregate)

  6. Research and Analysis – Sector/Facility Specific • Standard setting and permitting processes • BREF/BAT analysis • UK/US permit comparisons • Non-traditional elements of PPC permits, e.g., EMS, P2, energy, stewardship • Administrative costs/benefits • Environmental results

  7. Focus on Selected Sectors • Pulp and Paper • Pharmaceuticals (Organic Fine Chemicals – Batch Production) • Organic Chemicals (Large Volume Continuous Production) • Possibly 1–2 others

  8. Questions we’re asking: • Does an integrated approach to permitting deliver overall better environmental protection? • Does an integrated approach to permitting result in better environmental and economic performance by the permittee? • Is the overall administrative cost to government less when there is only one permit and one permitting authority? • Is the overall administrative cost to the permittee less where there is only one permit and one permitting authority?

  9. Questions we’re asking? • How are the facility-specific requirements (e.g., permit conditions) derived? • Does a holistic approach to facility-specific permitting result in better management of cross-media transfers and multi-media impacts? • How is change managed under an integrated permit? Changes to facility, changes to requirements, changes in the environment?

  10. Of interest in what we’ve seen so far… • Permits are comprehensive but relatively short compared to US permits. • Fundamentally different approach to environmental management: US – just meet standards; UK – BAT for everything beginning with management and only checking at end that standards are met. • Guidance and tools for permittees and permitting authority are exceptional.

  11. Of interest in what we’ve seen so far… • Permit development is much more collaborative because the goal is continuous improvement, not just compliance. • UK has an approach to change management similar to our “flexible air permits” – e.g., multi product protocol (MPP). • Because permits don’t expire, managing permits is more collaborative and less adversarial.

  12. Web Links • US EPA’s Innovative Environmental Permitting Site http://www.epa.gov/permits/integrated.htm • UK EA Site http://www.environment-agency.gov.uk/?lang=_e • OPRA Methodology and Spreadsheet http://www.environment-agency.gov.uk/business/444217/444661/444671/466170/411964/?version=1&lang=_e • EU sites http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=en&numdoc=31996L0061&model=guichett&lang=_e http://europa.eu.int/comm/environment/ippc/

  13. Conclusion: Potential Application of EU/UK Concepts and Tools • Plan to make recommendations to EPA senior management following research and analysis • Integration won’t happen overnight – UK has been doing multi-media permitting for 20 years or more • Incremental approach by States and EPA • Opportunity today to share ideas and make connections

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