From August 8 to date, no Ukrainian enterprise has submitted an application to the Ministry of Economy, Environment, and Agriculture for an Integrated Environmental Permit (IEP).
This was reported to EcoPolitic by Bogdan Semenko, Director of the Department of Industrial Pollution Prevention and Climate Policy at the Ministry of Economy.
The matter is at the consultation stage
For now, the Ministry has organized consultation work. They emphasize that in addition to general training, they are ready to provide individual answers to questions regarding obtaining an Integrated Permit. To do this, they advise submitting an application through the tools of the Unified State Register of IPs.
EcoPolitic was also told that in the future (though the timing is still uncertain), the Ministry's website will be filled with useful information on obtaining an IEP. In particular, this includes the most popular questions about the procedure and contact details of employees for prompt consultation.
“The Ministry has been and remains open to dialogue with all interested parties. As you can see, we regularly hold trainings and round-table discussions to inform about the progress of implementing the industrial pollution prevention reform,” Bohdan Semenenko noted.
The electronic state register of IDDs is a single window for submitting documents to obtain a permit. The Ministry has announced that it has already been tested and is functionally ready to accept applications.
Why businesses should not delay
The procedure for obtaining an IDD is new for Ukrainian entrepreneurs. Therefore, experts strongly advise businesses not to wait until the deadline and to actively seek advice and collect documents now.
“In the last year of the three provided for by the legislation, when all operators start submitting applications simultaneously, there will really be a risk of not meeting the deadline, as the permitting authority may be overloaded. At the same time, the first operators to submit applications may receive more attention and support from the permitting authority in terms of the consultations provided for by the law,” said earlier to EcoPolitica project coordinator of “Best Available Techniques and Management Methods (BAT) for Ukraine” Andriy Hunko.
In his opinion, the procedure has already been refined in the EU and successfully integrated into Ukrainian legislation; therefore, from a timing perspective, businesses should not face any difficulties.
Meanwhile, the mechanism itself comprises numerous nuances with which businesses must familiarise themselves from the ground up.
“The procedure for obtaining an Integrated Permit is more complex than some might assume. In fact, it is necessary to prepare a package of documents that should be submitted to obtain all three existing permits – for emissions, special water use, and waste operations,” reported to EcoPolitic the Head of the Center for Ecology and New Technologies Development, Vladyslav Antypov.
The expert notes that timely receipt of an IDD requires strong teamwork involving specialists. However, he is also convinced that if action is taken quickly, Ukrainian businesses will meet the deadlines even under martial law.
What is an IEP?
At the beginning of August, Law No. 11355 on industrial pollution came into force. This European integration document obliges Ukrainian enterprises to obtain permits under a fundamentally new scheme.
An integrated environmental permit (IEP) essentially combines all the permits that an enterprise previously obtained. In addition, under the new law, an IEP must be obtained not for the entire production facility, but for each specific installation that has an impact on the environment.
In early July, the government published a list of requirements and documents that must be included in a company's application for obtaining an IEP. Information is also already available regarding the format and content of the baseline report for obtaining an IEP and the reports that the installation operator is required to submit annually.
