Select Committee on Environment, Food and Rural Affairs Minutes of Evidence


Thomas Swan & Co Ltd
Supercritical fluid plant—IPPC permit application

  A valid application for the above permit was made on 4 May 2001. The permit was finally issued on 25 January 2002. This note attempts to draw out some preliminary learning points prior to a full assessment of the wider implications for the IPPC application process.

  The time to process the application appears to be inordinately long. This is probably due to:

    1.  The novelty of the process.

    2.  The novelty of the IPPC regime.

    3.  Overstretch of the inspectorate within the Agency.

  There were delays as a result of information being requested and subsequently not being required (DTI Industry Profiles to assess historical contamination for the site report).

  The use of Schedule 4 questions left us concerned on two counts:

    1.  They could become a way of managing workflow within the Agency by passing the "ball" back to the Applicant.

    2.  There is a lack of clarity about when the questions have been answered satisfactorily. This leads to uncertainty about the point at which the Agency needs to seek an extension to its determination time.

  The "rules" changed during the application evaluation. We were required to erect a permanent platform with stair access for flue monitoring although the ladder access was acceptable in the early stages.

  Although many of the exchanges between the company and the Agency were by e-mail we were (some days after the e-mail containing information had been received) required to send hard copies. This added to the delay. The Agency needs to clarify its approach to the use of e-mail as a means of communication.

  During the application the Agency removed the designation "Confidential" without our consent (although we would have consented) from a site map. They were able to do so by scanning and editing the image.

  The (initial) separation of account manager and permit officer led to initial delays. They become one and the same person in time (because of internal Agency resource constraints), but the principle of separation will not be helpful.

  Given the development nature of the plant, and thus its size and potential environmental impact we believe that a sense of materiality and proportionality was not in evidence.

  A more thorough assessment of the learning points from this permitting experience is being undertaken by the Agency and the Company.

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Prepared 15 July 2002