Environmental pig permits: Everything you need to comply
Pig farmers must comply with new requirements for environmental permits from 21 February, with key changes relating to slurry store coverage and ammonia emissions reporting.
With an increasing number of producers investing in expansion or making improvements to their pig accommodation to help ensure their businesses are sustainable, more units might need an environmental permit.
The trend is being driven by a combination of price pressures, the removal of the Basic Payment Scheme, and customer demands to continue improving welfare and environmental protection.
See also: Free emissions calculators for permitted pig and poultry farms
We find out more about the permit application process, the latest changes and ways to comply.
1. Who needs a permit and why
The Environmental Permitting Regulations apply to pig units with more than 2,000 pigs above 30kg or more than 750 sows, including served gilts. Permits are also required for poultry units of more than 40,000 birds.
Permitted units have to adopt minimum standards of management practice and Best available techniques (BAT) for nutrition, housing systems and slurry management, to minimise emissions and environmental pollution.
In 2017, a new best available techniques reference document was released by the EU Commission, and this month sees the final deadlines for permitted pig producers to make any changes required to comply with the BAT conclusions.
The UK farming industry has been given a target to reduce ammonia emissions by 16% by 2030.
If ammonia is released into the air in high concentrations, it can have damaging effects on plants and habitats. Deposition of nitrogen at the majority of designated sensitive habitat sites currently exceeds recommended safe levels.
2. Key changes
Ammonia emissions
Pig producers will be required to report ammonia emissions annually, in a similar way to their Pollution Inventory reporting. Emissions need to be submitted between 1 January 2022 (when the online system opens) and 28 February 2022, using data from 2021 (data for 2020 will be reported as per previous requirements).
Ammonia emissions will have to comply with updated BAT Associated Emission Levels (AELs).
However, the existing emissions factors used to calculate emission levels for UK pig farmers are at least 20 years out of date.
The Environment Agency (EA), which is responsible for enforcing Environmental Permit Regulations in England, is currently working with Defra to update emissions factors for different pig farming systems, and is using data from AHDB’s accelerated ammonia monitoring trials, presented in December.
The data shows that emissions factors – measured as 1kg of ammonia an animal place a year – are generally much lower on pig farms today, and suggests the majority of farms should be compliant with the new target emissions levels.
There remain some housing types – sows on slats and some farrowing sites – where the new data, along with the existing emissions factors, do not indicate compliance with the BAT AELs. The EA is working on the implications of this for existing sites and newly permitted sites in the future.
Slurry store coverage
From 21 February 2021, all permitted producers are required to cover slurry stores or lagoons, or use alternative techniques if they can demonstrate an equivalent level of environmental protection.
The EA has extended the deadline for when farms have to cover slurry stores with less than 1% dry matter (DM) to 21 August 2022.
Previously, permitted farms which could demonstrate that their slurry had a DM content of less than 1% did not need to cover their slurry stores. However, this position has been withdrawn because the EA found no evidence to support its continued use.
Stores that contain wastewater only will not need a cover. Wastewater can include yard run-off and wash-down water, providing it has not been combined with any slurry or run-off from farmyard manure (FYM).
If upgrading slurry storage, farmers also need to be aware of the 2018 farming rules for water. It is likely producers will need to provide clear justification for spreading FYM in autumn, which could affect their storage requirements.
Key dates and deadlines
- 21 February 2021: Slurry stores need to be covered
- 1 January 2022 to 28 February 2022: First annual ammonia emissions reporting
- 21 August 2022: Extended deadline for slurry stores with less than 1% DM to be covered
3. First step for applications
The first step in the permit application process should be to get in touch with the EA, says Yorkshire Farmers technical director Lizzie Bentley, who looks after permitting, assurance and compliance for its members and other farms.
“The sooner farmers contact their EA officer for advice, the better – whether that’s directly or through an adviser,” says Mrs Bentley.
“The process is not quick. Environmental permitting is becoming ever-more detailed, and advice will vary hugely depending on the particular system and location of the farm, whether it’s a new application or variation to an existing permit.
“You may not always know your exact pig numbers or precise system when you start the planning process, but it’s much better to screen for the highest potential environmental impact from the start, to avoid cost or delay later.”
The EA’s permitting service offers producers basic pre-application advice to help get permit applications right the first time, with some services at this pre-application stage free to access. Requirements of other legislation can influence options, for example, SSAFO (storing silage, slurry and agricultural fuel oil) and the farming rules for water.
4. Future-proofing
Mrs Bentley advises future-proofing a permit application as far as possible, to help avoid costly permit variations and avoidable delays in the future.
“Ask yourself where you would like your business to be in the foreseeable future, thinking about maximum pig numbers, unit footprint and location. To achieve the full permitted potential might involve several planning permissions over time.”
5. Slurry coverage options
Solutions could include separate wastewater and slurry stores or tanks, and tensioned or floating covers for slurry stores.
Other alternatives are natural crusts or straw covers, which must be managed effectively to make sure slurry is fully covered. If using straw, it needs to be kept topped up and prevented from blowing away.
6. Ammonia reduction options
Technologies such as air scrubbing, slurry cooling and slurry acidification are options for producers to consider in order to reduce ammonia emissions on planned or existing units.
Air scrubbing removes ammonia as air leaves the building, while slurry cooling and acidification both reduce ammonia at the source, which can also help improve the pigs’ environment inside the shed and provide other benefits, such as the improved value of slurry and odour reduction.
7. Permitting fees
A new permit application costs £8,020 and the annual subsistence charge is £2,386. For Pig and Poultry Assurance Scheme members, the subsistence fee is £1,444.
There may be additional charges. For example, the fee for reviewing an ammonia modelling report is £620 and, likewise, for reviewing a bio-aerosol management plan.
Help and information
In light of the new BAT conclusion in 2017, the EA has been reviewing all existing permits and hopes to issue the “permit variations” for pig units in the next few months. It also expects to release updated “How to comply” guidance for farmers in the next six months, and will work with individuals to help them continue to comply.
There are application templates and a podcast with the EA explaining what producers need to know at:
- ahdb.org.uk/knowledge-library/environmental-permitting-regulations
- Full details of the permit application process are online at gov.uk