IPPC: when does an operation need an integrated permit

What is IPPC and an integrated permit

IPPC stands for integrated pollution prevention and control. In Czech law this is mainly the regime under Act No. 76/2002 Coll., on integrated prevention.

The purpose of an integrated permit is to assess operation as a whole. Air, water, waste and noise are not addressed separately, but in their mutual relationship. The authority sets binding operating conditions so that environmental protection is ensured as a whole.

For the operator, the essential point is this: if an installation falls within the IPPC regime, it cannot be operated on the basis of partial permits alone. It must have a valid integrated permit.

An integrated permit usually replaces several sector-specific decisions, approvals and opinions. In practice it mainly addresses air emissions, wastewater discharge, waste management, noise, emergency conditions, monitoring, operating records, operating rules and obligations on cessation of operation.

When should an operator take notice

IPPC must be addressed whenever an operation or project may fall within one of the activity categories in Annex No. 1 to Act No. 76/2002 Coll.

It is not enough to rely on a sense of whether the operation is large or small. What matters are the specific categories and threshold values. These usually relate to designed or production capacity, thermal input, quantity of waste, bath volume, solvent consumption or number of animals.

Particular attention is advisable for large combustion plants, waste management installations, landfills, chemical production, electroplating shops, surface treatment, foundries, metallurgical operations, cement, lime, glass and ceramics production, large food-processing operations and intensive poultry or pig farming.

In practice: IPPC is not assessed according to the company name or whether the operation has a stack. The specific installation, technology, capacity and related activities at the given site are assessed.

Quick orientation overview of thresholds

The overview below does not replace a legal assessment, but helps to quickly identify when it is worth checking the IPPC regime.

The values given must always be related to the specific activity in Annex No. 1. Some operations may fall under IPPC even when the main technology appears simple, but a related activity exceeds a separate threshold.

Watch capacity, not just actual operation

A common mistake with IPPC is to assess only actual average operation. Threshold values, however, typically relate to designed or production capacity.

This is important, for example, for waste installations, food processing, combustion plants, livestock farming or batch technologies. Operation may routinely run at lower output, but if the permitted or designed capacity is higher, the IPPC regime may apply.

The operator should therefore distinguish actual average operation, maximum daily or hourly capacity, designed capacity of the installation, capacity stated in permits and capacity to be stated in a new application or documentation.

If these figures differ across documents, there is a risk of unclear classification.

Aggregation of capacities

Another frequent problem is aggregation of capacities. If several activities falling under the same activity description with a threshold value are operated within the same installation, capacities may be aggregated.

This is typically addressed for multiple lines, multiple boilers, multiple technology nodes, multiple waste operations or multiple related operational parts within one site.

The operator should therefore not assess each smaller line in isolation if together they form one operational whole. What matters is technical and operational connection, common location and link to the main activity.

For waste, aggregation is especially important for activities under points 5.1 and 5.3 of Annex No. 1. Incorrect splitting of capacity across several parts of the operation may lead to the wrong conclusion that IPPC is not required.

What IPPC replaces and what it does not replace

An integrated permit replaces a number of sector-specific decisions under component legislation. In practice this can be advantageous because the operator has the main environmental conditions in one decision.

That does not mean, however, that IPPC replaces everything. EIA, building proceedings, zoning compliance, occupational safety, fire protection, emergency planning, chemical legislation, water-management follow-up or other documentation may still need to be addressed according to the specific operation.

An integrated permit is therefore the central environmental permit for operation of an installation, but it does not exclude the need for further steps in the permitting process.

IPPC and EIA

IPPC and EIA are not the same thing. EIA assesses the impacts of a project on the environment before the project is permitted. IPPC sets binding operating conditions for an installation that falls within the integrated prevention regime.

For larger projects both are often addressed. The investor may first go through the EIA process or screening procedure and subsequently prepare an application for an integrated permit.

Data in EIA and IPPC should be mutually consistent. If the EIA states different capacities, different emission sources, different transport or a different operating regime than the IPPC application, problems arise in subsequent permitting.

What is assessed in an application for an integrated permit

An application for an integrated permit is not just a description of technology. It must show how operation will be managed, monitored and how environmental impacts will be limited.

In practice the following are mainly addressed: description of the installation, main and related activities, capacities, operating regime, raw materials, fuels, energy, water, air emissions, wastewater, waste, noise, emergency risks, monitoring, measurement, operating rules, records, BAT and measures on cessation of operation.

For the operator it is important to prepare documentation so that it is usable not only for submitting the application but also for later inspection. The conditions of the integrated permit will be binding and the operator will have to comply with them long term.

BAT and BREF: why best available techniques are addressed

Part of IPPC is assessment of best available techniques, i.e. BAT. This is not just a formal chapter. The authority compares the operation with BAT conclusions and on that basis sets emission limits, monitoring and other operating conditions.

BREF documents and BAT conclusions are important especially for large combustion installations, waste, chemicals, food processing, metal processing, surface treatment, livestock farming and other activities under Annex No. 1.

The operator should know in advance whether BAT conclusions exist for their main activity and what requirements follow from them. For older operations there may be a problem if the installation has long failed to meet newer BAT requirements and technical modification, change of monitoring or change of limits will be necessary.

Existing operation and change to an installation

IPPC does not concern only new operations. It is very often addressed for existing installations planning a change.

A change may be capacity increase, a new production line, technology change, fuel change, addition of a combustion source, change in waste management, extension of storage, change of emission sources, change of wastewater or a new operating regime.

The operator of an installation with an integrated permit has a duty to report planned changes that may have consequences for the environment. The authority then assesses whether it is a substantial change, a change to the integrated permit, or whether a simpler procedure suffices.

In practice: If you already have an integrated permit, do not address changes only after they are implemented. First compare the project with the operative part of the permit and the binding operating conditions.

Most common mistakes from practice

The most common mistake is that the investor addresses IPPC late. The project is prepared, capacities set, technology ordered and only subsequently is it found that the operation falls within the integrated permit regime.

A second common mistake is assessing only the main technology. For IPPC, directly connected activities are also important, for example storage, waste treatment, wastewater treatment, energy, landfills, handling or auxiliary operations, if they are technically related and may affect emissions or pollution.

Another problem is unclear capacity. A different value is stated in the project than in the EIA, a different figure in the waste permit application and another value in the commercial technology proposal. For IPPC capacities must be aligned and explained.

A frequent mistake also occurs with changes to existing operations. The operator assumes that because they already have an old integrated permit, a new modification will fit within it. That may not apply. What matters is the operative part of the permit, permitted capacities, emission sources and binding conditions.

What documentation to prepare for an initial assessment

For an initial assessment it is not necessary to have the complete application ready. Basic technical data on the operation must, however, be assembled.

For waste installations it is important to provide also waste catalogue numbers, handling method, daily and annual capacities, technological operations and description of outputs. For energy the total rated thermal input is essential. For livestock farming the number of animal places. For surface treatment bath volume or solvent consumption.

How to proceed when you are unsure

If it is unclear whether the operation falls under IPPC, it is advisable first to carry out a classification assessment. That means comparing the actual or planned operation with Annex No. 1 to the Act on integrated prevention.

The assessment usually addresses three questions:

1. Does any main activity fall under Annex No. 1?
2. Does designed or production capacity exceed the relevant threshold value?
3. Are there related activities on the site that should be included in the installation?

If the answer is not clear, it is advisable to prepare documentation for consultation with the relevant regional authority. For more complex operations it may be better to verify classification in writing before submitting applications in subsequent proceedings.

What you can send us for assessment

Send us a brief description of the operation, technology diagram, capacities, site layout drawing, waste list, overview of emission sources, data on water, noise, existing permits and information on whether it is a new project or a change to an existing installation.

From the documentation we will verify whether IPPC may apply to the operation and what steps it will be appropriate to prepare. We will also assess whether EIA, change to existing permits, expert documentation for air, water, waste, noise or an application for an integrated permit will need to be addressed.

More on environmental services can be found on the NATURCHEM Services page.

Brief summary

An integrated permit is required when the operation falls within one of the activity categories listed in Annex No. 1 to Act No. 76/2002 Coll. and reaches the relevant threshold values.

The operator should first verify the main activity, capacity, related operational parts and existing permits. It is not enough to address only one line or one stack. IPPC assesses the whole installation and its impacts on the environment as a whole.

The greatest risk arises for larger investments, waste installations, energy, chemicals, surface treatment, large livestock farming and operations that gradually increase capacities. For these projects we recommend verifying the IPPC regime right at the start of preparation.

Factual basis of the article

From the above sources it follows that IPPC must be addressed technically and in terms of capacity, not merely administratively. What matters is the actual operational whole, its designed capacity, related activities and impacts on the environment. In unclear cases it is advisable to verify classification in good time, before subsequent permitting proceedings begin.