What is Integrated Permitting?
     A growing number of other countries are using "integrated" permits, which control all elements of a facility's
     environmental "footprint." Emissions to air, water, and land are comprehensively managed, along with a host
     of other factors (such as waste generation, raw materials use, energy efficiency, noise, accident prevention,
     other pollution prevention factors, and risk management). Accounting for the whole facility's environmental
     impacts, an integrated permit goes beyond simply consolidating applicable media permits - it is intended to
     promote continually improving performance while ultimately driving the facility to more sustainable
     outcomes.
jo

The Integrated Permitting International Collaboration Effort
This international comparison presents an opportunity for the US to assess whether integrated permitting may
offer one way to achieve better environmental results, reduce regulatory burdens, or both. The United
Kingdom (UK) and European Union (EU), contemporary leaders in integrated permitting, have offered to
collaborate with the EPA by sharing their experience in Lransitioning to an integrated permitting system and
by helping EPA explore the potential for using such models in the US.

Taking advantage of this international invitation, EPA hopes to first assess what aspects of the European
approach might be translatable to the. US, building useful comparison models and assessment tools regarding:
(1) integrated permitting applications, operational and organizational approaches, and strategies; (2) areas of
commonality between the  European and US permitting practices; (3) die  US States' experimental permitting
experience, to date; and (4) benefits and costs of integrated  permitting: Lastly, EPA hopes to work with
interested States and industry partners to explore the potential use of integrated approaches in the US.
      UK and EU Experience
      The UK has been using integrated permitting since 1990, starting with the Integrated Pollution Control (IPQ
      Act.  The IPC required operators (for specified industries having the greatest potential discharges in one or
      more media)  to evaluate the potential impact of their processes and select the most practical options for
      minimizing pollution overall. In 1996, building on the UK experience, the EU adopted the Integrated
      Pollution Prevention and Control  (IPPC) directive, establishing basic rules for incorporating integrated
      permitting systems into the regulatory frameworks.

      The EU member states are currently implementing integrated permitting systems in compliance with the
      IPPC. The directive demands that regulators set levels for permit conditions to achieve protection for the
      environment  as a whole and calls for facilities to comprehensively account for all environmental impacts. The

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IPPC addresses 32 specific business sectors, including energy, metals, minerals, chemicals, waste management.,
pulp and paper, food and drink,, intensive agriculture, tanning, textiles., glass, and ceramics.

Under the IPPC, permit conditions must be based on the concept of Best Available Techniques (13AT). The
IPPC Bureau., based in Seville, Spain, organizes an exchange of information among experts from EU member'
states., industry, and environmental non-government organizations to produce BAT reference documents
(BREFs) foe each of the 32 sectors. Regulators must also take into account the technical characteristics of a
facility,, its geographic location, and local environmental conditions when writing a permit

In 2000, the UK began to phase in the requirements of the IPPC directive. The UK's new regime. Pollution
Prevention and Control (PPC), replaces the IPC arid should be fully implemented by 2007. The PPC is
outcome-focused, expands permitting considerations (adding, for example, energy use. and site restoration),
and includes additional sectors (such as, waste management, paper, food, and intensive agriculture).  The UK
also uses a risk-screening methodology based on the complexity, emissions, location, and performance of a
facility to target activities that present the greatest risk to the environment.  The UK  issued its first: PPC
permit in March 200:1 and has issued approximately  700 integrated permits to date.  An approximate 600
additional applications are currently being processed.
UK

ageticv.gov.uk

EU
httpV/curopa cu int/coiti/
enyirotuscnt/igpc/
IPC
implemented

40**





PPC
Implemented

300°

IPPC Directive
issued



49**


PPC to be fully
implemented

900*
IPPC to be
implemented
EU wide

&&
Participation in the Effort
A network of international, federal, and state regulators is being formed to undertake this exploratory effort
The team will include innovative permit-writers and policy and program experts from EPA's Regional and
National Program Offices, the Office of International Affairs, the National Center for Environmental
Innovation, and interested State agencies and industry. For further information in general or regarding
participation in this collaborative effort, please  contact Lisa Comer in EPA's National Center for
Environmental Innovation at 202-566-2206 or at comedisa@epa.gov.

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