Does my Mobile Plant require an Environmental Permit?
A regulated facility will be either an installation, a waste operation (other than as part of an installation) or a mobile plant.
Mobile plant is defined in regulation 2 as plant which:
Is not an installation
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is used to carry out any activity or any waste operation, and
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where not used to carry on a Part A activity, is designed to move or be moved whether on roads or other land
If anything that you do was covered by the PPC regime, then the new Environmental Permitting Regulations will also apply to you.
If you have an existing PPC permit, it will have automatically become an Environmental Permit on 6 April 2008. You do not need to reapply and your permit will contain the same conditions as before.
Mobile Treatment Licences
Changes like the Landfill Directive have significantly increased the cost of disposing of contaminated soils from contaminated sites. This has encouraged the use of on-site treatment plants for contaminated soils. The treatment of contaminated soils and contaminated controlled waters is a licensable activity.
The licence used, in most cases, to regulate this activity on site (either in-situ or ex-situ) is a Mobile Treatment Licence or MTL, as opposed to a site licence.
The Mobile Plant Licencing System:
The EA has redesigned the Mobile Plant Licensing system to encourage operators to redevelop brownfield land in a more economic and timely way, without compromising on environmental protection.
It is the E.A’s policy to regulate all remediation activities using Mobile Treatment Licences, where the remediation technology is mobile as defined above. Fixed remediation techniques are not covered e.g. permeable reactive barriers.
The new approach includes:
A single licence that allows operators to use several pieces of mobile plant, either singly or in combination, at the same time on different sites.
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a "deployment form" that means operators can identify all key data including their account manager, site specific information and a guide to what other permits they may need.
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Changes in the charging method for Mobile Treatment Licences
The primary objective of the Mobile Treatment Licence is to prevent harm to human health, pollution of the environment and or any deterioration in the local area amenities, stemming from the activity that the MTL authorises.
Strictly speaking the legislation talks about Mobile Plant Licences. However,
over the years it is evident that what is actually being regulated is the remediation technologies themselves, and not the various bits of plant associated with that technology.
The list of specified plant within the regulations has been amended (July 2005), from the
treatment of waste soil only, to the much broader definition:
“plant for the treatment of contaminated materials, substances or products, for the purpose of remedial action with respect to land and controlled waters”.
In addition to the above, the following plant will also be relevant:
“plant for the dewatering of muds, sludges, soils and dredging, and
plant for the treatment by lime stabilisation”.
Abricon will assist you to determine whether or not your plant requires Mobile Treatment Licence, and will guide you through the necessary paperwork.
Note that you will require additional licences if carrying out the above activities using waste materials, and that Abricon can assist with both applications simultaneously, saving you considerable time and expense.
Contact Abricon for free initial advice on these and other environmental permitting issues.
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