Ascending to IED compliance If you identified via our ‘Cones of Pain’ diagram / ‘IED: IN or OUT?’ guide that you need to comply with the Industrial Emissions Directive (because you have more than 50MWth combustion capacity), then we have put together this useful summary on the steps to compliance with IED. Once permitted, comply with on-going monitoring and reporting requirements and pay annual fees Step 4 – Submit the Application to the Environment Agency and pay EA fees The Application Application Form – Standard Environment Agency template forms Non-Technical Summary – Summarises key aspects and findings of the supporting information Best Available Techniques (BAT) Assessment – Technical assessment to establish the suitability of the activities on site against published technical guidance documents. Environmental Risk Assessment – risk assessment undertaken against set criteria. Atmospheric dispersion modelling assessment – to assess potential impacts on air quality from operation of generators under different conditions. Site Conditioning Report – to assess current conditions and provide a baseline document such that the condition of the land can be monitored. The Operator Risk Assessment assesses the risk of the proposed facility. This will inform the EA fees associated with the Permit. Step 3 – Prepare the Application and complete the OpRA Profile Step 2 – Identify the boundaries of your permitted facility (The Aggregation Rule) The Aggregation Rule All the combustion plant (i.e. generators) on site should be aggregated together to check if the ‘facility’ exceeds the 50MW thermal input threshold. The permitted ‘site’ could have different boundaries to that in CCAs or EU ETS if the combustion plant is scattered over an area. For example, two data centres operated by the same company on different sides of a road or campus could be an aggregated facility and therefore the operator would need to consider all combustion plant across the two sites to check whether the IED 50MWth threshold is exceeded. It is up to data centre companies to consider this rule and propose suitable boundaries in the permit. The EA is concerned with environmental impacts so they will be looking out for things at one data centre that could give rise to the same environmental impact at another. Step 1 – Notify the local Environment Agency Officer (directly or via techUK) Much better to let the EA you are addressing your compliance rather than them coming asking you why you’re not