MANUAL OF ENVIRONMENTAL POLICY: THE EU AND BRITAIN

In January 1991 the Council of the OECD (Organization for Economic Co-operation and Development) adopted a Recommendation6, 7 that member countries practise integrated pollution prevention and control. The preamble to the Recommendation recognized that substances can move between environmental media (air, water, soil and biota) as they travel along a pathway from a source to a receptor, and that controls over releases of a substance to one environmental medium can result in shifting the substance to another medium. Guidance notes accompanying the Recommendation explained the concept in greater detail and explain that an integrated approach involves a shift from the traditional focuses for decision making (i.e. the individual media) to the substance, the source and the geographical region. It also gave examples of measures, such as issuing single permits, covering all releases, and the use of inventories of releases, which when coupled with inventories of inputs enable a ‘mass balance account’ to be drawn up.

The most significant source oriented development has been the 1996 IPPC Directive (Section 6.18). This requires a single permit to be issued for installations covering a wide range of industrial plants covering emissions to air, water, the generation of waste, energy efficiency and raw materials use, with the objective of minimizing impact on the environment overall. The Regulation establishing a voluntary eco-management and audit scheme (EMAS) (see Section 11.8) should also stimulate a more integrated approach since it requires participants to think about all the impacts of their plants. The IPPC Directive explicitly encourages operators and regulators to link EMAS to the integrated environmental assessments under the Directive.

The integration of environmental protection requirements within IPPC results in a requirement for a regulator to press for strong emission controls, while taking account of environmental quality standards. Actions which separate these two approaches is no longer appropriate. This link is made explicit in Article 10 of the water framework Directive (see section 4.15), where Member States would be required to take the ‘combined approach’ to pollution control.