Industry environmental self-monitoring and reporting UK experience with reference to the Pollution Inventory

1. Industry environmental self-monitoring and reportingUK experience with reference to the Pollution Inventory Dr Ian Whitwell The Environment Agency of England & Wales (www.environment-agency.gov.uk/pi)

2. Introduction • The Environment Agency is the main competent authority for regulating large industrial activities in England and Wales • Pollution Inventory established in 1998 - a Pollutant Release and Transfer Register or PRTR. Not compliance check • Rio Agenda 21, US Toxic Release Inventory, UK Chemical Release Inventory • Records annual mass releases and transfers from the industrial activities that we regulate • Other PRTRs in UK - not fully integrated yet

3. Objectives To satisfy the needs of stakeholders requiring information on releases to the environment (includes UNECE, EC, UK government, citizens, NGOs, industry). To do this we: • Provide data and information on releases to the environment and their possible impact in a scientifically valid and transparent way, with easy access, set in its proper context, to a general audience • Use the information to evaluate regulatory policies and the benefits of regulation • Provide feedback on environmental performance and contribute to industrial benchmarking • Collect data in a consistent and cost-effective way (proportionate to the objectives)

4. Principles • Mandatory requirement to report industrial releases for specified substances • Reporting requirements should be clear and open and should not be a back-door route for requiring additional monitoring • The best information to be provided without causing excessive burden • Industry consulted when changes are to be made • Operator responsible for providing information, not the regulator, ie self-monitoring • Include international PRTR requirements

5. Data (releases and transfers) Development of the Pollution Inventory Driven by legislation e.g. Aarhus, IPPC • Drivers include: • National PI • EPER/E-PRTR • UNECE PRTR Public and stakeholder expectation Environmental issues • Coverage includes: • process industries: mainly IPPC • wastewater works • radionuclide sites • Coverage includes: • substance information • burden measures • risk-based information • site-specific commentary Activities (sources) and locations Contextual information NOT just data

6. Scope • Most IPPC Annex 1 activities • Large wastewater treatment works • Sites with releases of radionuclides • Around 170 reportable substances or groups - multimedia • Reporting threshold set to capture 95% of emissions from the activities we regulate • releases below reporting threshold defined as ‘brt’ • no release is defined as ‘not applicable’ (n/a) • Measured, calculated, estimated • Data collected, entered and verified locally; some centralised checking • Some commercial-in-confidence and national security issues

7. Air Reportable media Off-site waste transfers Land Air Sewer Wastewater treatment Water Other disposal

8. Activities reporting

9. Legal and institutional issues • Reporting mainly from activities permitted under IPPC • Pollution Prevention and Control (PPC) Act and Regulations determines competent authorities and the activities required to report • Competent authority determines specific sites for permitting • Reporting requirements defined in Information Notices rather than in the permit itself - flexible • Notice issued every 3 years • Can change requirements without varying permit conditions • Pollution Inventory Advisory Group

10. Electronic reporting screen

11. Reporting guidance and tools • Concerns over lack of reporting • Assist by producing guidance and reporting tools: • recommend measurement techniques • MCERTS certification (www.mcerts.net) • Operator Monitoring Assessment (OMA) scoring • define alternative calculation and estimation methods (emission factors, mass balance etc) • General and sector specific • Jointly funded working groups (industry and regulator) • Highlights most relevant substances, but operator has responsibility to report all relevant releases • Currently use of the guidance is not obligatory • Available from our website (www.environment-agency.gov.uk/pi)

12. Guidance and tools - eg landfills • Landfill leachate estimator tool • Landfill gas emissions estimation tool - GasSim

13. Quality assurance and checking • 26 Areas • Three levels of checking • Area Inspectors using site-specific knowledge • Centralised using trend analysis • Operators have opportunity to view and amend prior to publication • Some experience must be built up before QA methods can be fully developed

14. Public information - WIYBY • PI data published annually on website • ‘What’s in Your Backyard’ - WIYBY • Easily accessible by stakeholders • Downloadable • Maps • Comparisons • ‘Spotlight on industry’ report

17. Contextual information Substance information sheets

18. Contextual information Burdens - Global Warming Potential for releases from activities we regulated in 2000

19. Lessons learnt • Monitoring not obligatory for PI • Legal clarity needed. What and by when? • Consult with industry • Guidance and tools • joint funding • consistency • Context • Regulation by information • Advisory Group with stakeholders • Highlight benefits to industry - public image