Integrated Environmental Authorization for dummies

Are you an environmental dummie? Do you want to know what Integrated Environmental Authorization is in a minute? Don't stop reading, maybe you don't quite understand it, but we'll give you a solution.

As an entrepreneur you may find that your activity needs an Integrated Environmental Authorization, or for various reasons request a modification of it.

Where to start

It's normal that we don't know where to start, what requirements you must meet, or what documentation to submit. Well, here is a short summary of the steps to follow to carry out the application process for the Integrated Environmental Authorization or its modification.

First, the regulations.

First of all, we must know what exactly the Integrated Environmental Authorization is, what it is for and what facilities are subject to it. According to Royal Legislative Decree 1/2016, of 16 December, approving the consolidated text of the Integrated Pollution Prevention and Control Act, the Integrated Environmental Authorization (AAI) is defined as:”The written resolution of the competent body of the autonomous community in which the facility is located, allowing, for the purposes of protecting the environment and human health, to operate all or part of an installation, under certain conditions designed to ensure that it complies with the object and provisions of this law. Such authorization may be valid for one or more facilities or parts of facilities that have the same location.”

Legislative Decree 1/2016 also establishes in its article 2 the scope of application: “this law shall be applicable to publicly or privately owned facilities in which any of the industrial activities included in the categories listed in Annex 1 and that, where appropriate, meet the capacity thresholds established therein, with the exception of facilities or parts of them used for research, development and experimentation of new products and processes”.

Who asks me for it and what should I submit.

The request for the AAI must be made to the competent body of each autonomous community and specific documentation must be provided about the activity. One of the most important documents to be prepared is the Basic Project of the Activity which contains a detailed description of the activity, the facilities and processes, the raw materials and natural resources used, the description of the physical environment and the expected impacts on it, the sources that generate emissions and waste and the systems for controlling emissions and discharges, among others.

In addition, within this Basic Project, a analysis of the best available techniques (MTD). And what are the best available techniques or MTD? MTD are the most effective technologies for environmental protection developed for application in each industrial sector and are compiled in European reference documents (BREF documents) and in Decisions on the MTD conclusions, and it is on the basis of them that the emission limit values of pollutants are established.

And if I already have my Integrated Environmental Authorization, what?

It may be the case that our activity already has the Integrated Environmental Authority and changes are going to be made to the production process, such as increasing capacity or modifying the processes or raw materials used in it. In this case, you must submit a request for modification of the authorization, which can be considered substantial or non-substantial depending on the criteria described in Article 14 of Royal Decree 815/2013, of October 18, approving the Regulations on industrial emissions and the development of Law 16/2002, of July 1, on integrated pollution prevention and control.

In the event that the modification is considered to be substantial a basic project must be submitted together with the request, including the part or parts of the facilities that are affected by the modification, the possible impacts that are expected and the measures to control emissions to the environment, as well as other documentation relating to water regulations, MTD, and any other documentation that accredits compliance with established requirements.

It is important to highlight and keep in mind, that in the event that there are several successive non-substantial modifications to the installation, and the sum of two or more of them meets the criteria established for the consideration of a substantial modification, the modification will also be considered substantial.

The Integrated Environmental Authorization Resolution.

Finally, let's see what is included in the resolution of the Integrated Environmental Authorization. This resolution sets out operating conditions, as well as limit values for the emission of pollutants, procedures for waste management and prescriptions for the protection of soil and groundwater, systems and procedures for the treatment and control of emissions and waste.

In the AAI It also establishes the measures to be taken for operating conditions other than normal, the conditions under which the cessation of activities or the closure of the facility will take place and the notification requirements to the competent authorities, among others.

If you need advice on Integrated Environmental Authorization, at Environmental Ideas we have specialized technicians with almost 20 years of experience in this type of procedure, at your disposal.