Manual on the Development of Cleaner Production Policies ... - Unido

DEVELOPMENT OF CP POLICY
MODULE 5: POLICY TOOLS AND INSTRUMENTS
SLIDE: CP in permitting, enforcement and financing support
• Environmental permitting may include elements of CP;
• Environmental inspectors could promote CP;
• Implementation of CP programmes is mandatory in enforcement actions;
• Financial assistance for environmental investments could require a prior
CP assessment.
This slide presents how CP and pollution prevention can be incorporated into
the permitting process, enforcement actions and decisions on providing
financial support to companies. The key message is that there already exist
proven ways to make CP an integral part of regulatory mechanisms.
Background
Cleaner production has traditionally been considered a voluntary initiative, left to companies to adopt
if they consider it appropriate. In contrast, obtaining environmental permitting and complying with the
regulations are obligations that have to be met. However, enforcing regulations and complying with
prescriptive laws are both costly to all parties involved.
Consequently a number of countries have decided to make CP (or pollution prevention/source
reduction) an integral part of the permitting process. Some of the strategies that have been used to
promote CP and prevention in the permitting process include pre-permitting interviews and
distribution of information, permit avoidance through CP, pollution prevention planning, or explicit
pollution prevention permit conditions.
CP in the permitting process
As part of permitting, firms may be required to undergo Cleaner Production audits of their plants and
to implement suggestions. In most cases, however, a CP review is a part of the process, and normally
not an obligation to implement all potential measures identified. The following list contains possible
approaches:
(a) Permit application form includes questions that would help the authorities determine if CP
potential exists in the applicant’s facility;
(b) Permit application package includes a brochure on the benefits of CP and contact information of
a CP technical assistance office;
(c) A permit can be issued stipulating that a CP programme must be developed in the first year of
operation, or even prescribe that companies must demonstrate that they have a waste
minimization plan in place at the beginning of operations. Typically, companies are then required
to submit annual progress reports;
(d) Reduced record-keeping, inspections or permit fees are applied to companies that implement a
CP programme;
(e) Environmental fees and charges are set to encourage implementation of preventive techniques;
(f) Some permits issued are based on an integrated analysis of processes rather than on
environmental media specific impacts.
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