Annex
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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