Integrated "Green" Licensing (IPPC)

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 Integrated "Green" Licensing (IPPC)

/PhotoAlbum/Air%20Quality/%d7%9e%d7%a4%d7%a2%d7%9c%d7%99%d7%9d/electrochemical_industry.jpgElectrochemical Factory. Photo: Ilan Malester
Electrochemical Factory 
Photo: Ilan Malester 

The ​Ministry of Environmental Protection (MoEP) is moving toward its goal of drafting an Integrated Environmental Licensing law, dubbed "the green licensing law". The law, to be based on the European Union's Integrated Pollution Prevention and Control (IPPC) Directive, will affect sectors with a significant environmental impact. It will streamline existing environmental permits into one integrated permit, thus creating one unified and simplified approval procedure. A "green license" would serve as a one-stop shop for businesses that need to apply for more than one type of environmental permit; it would remove obstacles such as bureaucratic and cumbersome licensing procedures, lack of centralized information, and inadequate government support, while providing certainty to the drivers of change in the industrial sector, facilitating high environmental performance and serving as a green track to innovation.

Background: A Tool for Green Growth

​The need for an integrated environmental licensing law was highlighted in the wake of a 2011 government decision - No. 3768 - on the preparation of a national green growth strategy for Israel. Three round tables were set up to implement the government decision – on production, consumption and innovation – and important insights were gleaned from each of them.

Discussions around the green production round table highlighted the fact that there need be no contradiction between industrial development and environmental performance. In fact, industry declared its readiness to improve its environmental performance based on pollution prevention at source, implementation of best available techniques (BAT), and efficient use of resources - in return for greater regulatory certainty.

In order for industry to move forward, however, new directions were needed to remove the obstacles such as bureaucratic and cumbersome licensing procedures, lack of centralized information, and inadequate government support. The main recommendation for dealing with these issues while promoting green growth in the manufacturing sector was creation of an advanced environmental regulation system through integrated environmental licensing. Thus, whereas currently, industrial activities are subject to different licenses issued by different units in the Ministry of Environmental Protection for different periods of time, the new approach will simplify the process, increase efficiency, and improve both the economic and environmental performances of these companies.

Israel based this new approach on the European Commission Directive on Integrated Pollution Prevention and Control (the 2008 IPPC Directive), which was replaced in late 2010 by the Directive on Industrial Emissions (IED Directive). The directive sets a target of prevention, or where not possible - minimization - of emissions to the air, water, and land from industrial installations, in a manner that will bring about a high level of environmental protection as a whole.

The directive is based on such principles as an integrated approach, best available techniques (BAT), flexibility, inspections and public participation. This also is in line with the commitment Israel made to implement IPPC as part of its OECD accession process, which was completed in 2010.

Relevant Government Decisions

  1. Govt. Decision No. 3768, Oct. 23, 2011: This resolution approved the proposal of the Ministers of Environmental Protection and Industry, Trade and Labor to prepare a National Green Growth Strategy for the years 2012-2020. The resolution defined green growth as "socio-economic growth and development that does not harm the environment, makes efficient, economical and sustainable use of natural resources, and creates green jobs while maximizing opportunities for using clean growth engines and emphasizing the decoupling of economic growth from environmental deterioration.
  2. Govt. Decision No. 708, Aug. 25, 2013: This resolution imposes upon the Prime Minister's Office the responsibility of formulating a program to improve the regulatory process and to reduce its existing bureaucratic burdens.
  3. Govt. Decision No. 1546, April 6, 2014: This resolution calls upon the government, in light of its accession to the OECD, to improve the regulatory process and to promote green growth, via promotion of an Integrated Environmental Licensing process. The resolution imposes upon the environmental protection minister the responsibility of formulating and distributing for approval a proposed Integrated Environmental Licensing law by December 31, 2014.

The Process and Its Advantages

Most factories need several environmental permits, which are issued by various units in the MoEP and its district offices. Thus, integration between the various licensing authorities is necessary, in order to reduce the administrative burden on industry and to increase the effectiveness of regulatory actions, as well as to allow a thorough and orderly process of environmental evaluation and regulation.
Under a green licensing system, criteria would be set for determining permit requirements, including pollution prevention, utilization of BATs, recovery or recycling of waste, proper treatment of hazardous materials, proper treatment of a factory site, etc. A business owner would need only apply for one permit, which will include all environmental conditions and requirements for that business. Once received - that permit would be valid for seven years, which is a longer period of time than current permits.
Even after a license is issued, the factory will be evaluated for its environmental impact. That evaluation will take into account all elements, including natural resource use. If it is determined that the impact exceeds the acceptable risk level, the business will be required to reduce that impact in the framework of the licensing process.
As a result of coordination of the permits and the permitting procedure:
  1. The permitting process will be more orderly, will present less of an administrative burden to the applicant, and will result in more certainty for the business owner.
  2. Pollution of air, water, soil, and noise will be minimized and efficiency will be increased, because there will be no way for pollution or energy/resource use to be shifted, once the industrial process is considered as one whole, by one entity, rather than separately. In addition, the process includes evaluation of the factory's environmental impact
  3. More transparency will result in a public that is better informed about the emissions and transfers, and their impact on the environment. Data about discharges from factories will be available to the public, and discharge permit drafts will be available for public comments.
  4. Innovation of environmental technology will be encouraged. Permit applicants will have to prove they are implementing BATs in order to receive a license. This requirement will inevitably incentivize many to seek more advanced and "greener" technologies. In addition, the MoEP will give the applicant the opportunity to conduct controlled pilot experiments (beta sites) for technological innovations within the framework of the BAT implementation program.


Learn more about environmental licensing in Israel.

Principles of a Green Licensing Law

​The main principles of the law, which encapsulates the principles of Israel's National Green Growth Plan for 2012-2020 are:

  1. Gradual implementation of advanced environmental standards in industrial installations and businesses, based on Integrated Pollution Prevention and Control (IPPC), the principles of which are detailed in the EU Industrial Emissions Directive EU/2010/75 (IED)
  2. Clear criteria and timetable to be adhered to by industrial installations and businesses dealing with permitting
  3. Reduction of administrative burden: simplification of administrative processes, with the aim of integrating environmental permits and licenses required from industrial installations and businesses through a process of coordination and unification, a process that will increase effectiveness and reduce "bureaucracy costs"
  4. Prioritization of pollution prevention at source and of environmental efficiency, in a way that will decouple the connection between production and environmental pollution, and will create opportunities for economic growth based on pollution prevention and on implementation of more effective green techniques and technologies
  5. Distribution of responsibilities between central and local government
  6. Evaluation of incentives for industrial installations and businesses that are leaders of change: evaluating the idea of incentivizing industrial installations and businesses to go beyond the minimum legal environmental requirements of preventing pollution and waste beyond required standards, through pollution prevention at source, environmental efficiency, implementing innovation and other steps
  7. Establishment of procedures to enable and incentivize the implementation of Israeli-developed environmental innovations, including testing and demonstration facilities, as well as initial commercial installations
  8. Development of evaluation mechanisms for technologies developed in Israel that are not recognized in EU reference documents (BREFs), for the purpose of recognizing them as emerging technologies that are applicable in industrial installations and businesses for compliance
  9. Implementation of the principle of public transparency in environmental permitting procedures; under this principle, information would be available to the public about the companies, their emissions, and the decision-making process of regulators.

Who is Affected by Integrated Licensing?

There are currently ​some 13,000 factories and businesses that must receive some sort of permit from the Ministry of Environmental Protection in order to obtain a license to operate. Most are small, with a local environmental impact; under the reform they will be placed in an expedited, or green, track, which will allow them to get permits without any waiting period. Some 2,000 are large or medium-sized factories that will be in the unique track, because specifications for these businesses must be individualized. More on Expedited and Unique Tracks.

About 250-300 are classified as large factories with a significant impact on the environment. It is only those factories that would be affected by a green licensing law. They mainly belong to the following industrial sectors:

  1. energy
  2. industrial chemicals
  3. metal production/processing
  4. minerals
  5. waste management and treatment
  6. fuel combustion in large installations
  7. food production and animal husbandry


Licenses and Permits Under the Authority of the MoEP

  1. Air emissions permits for activities that are detailed in addendums to the law will be issued for a 7-year period by the Air Quality Division.
  2. Business license for activities detailed in the Business License Decree will be issued for 1, 3, 5, 10, or 15 years, depending on the type of license, by local authorities, with the approval of the MoEP.
  3. Toxic materials permits for all activities related to amounts of poison that exceed those set in the Hazardous Materials regulations will be issued for 1, 2, or 3 years by an appointee of the minister of environmental protection.
  4. Permits for the evacuation of hazardous waste to any location other than the hazardous waste dump site in the Neot Hovav Regional Council.
  5. Permits for the discharge of waste or wastewater from land-based sources.

Twinning Guidance Project

​Within the framework of the European Neighborhood Policy, Israel is benefiting from two major instruments:

  1. TAIEX (Technical Assistance and Information Exchanges) provides short-term public assistance to beneficiary countries to deal with focused and targeted requests for assistance while the latter aims at upgrading the institutional capacity of the beneficiary country largely through training. More about TAIEX.
  2. Twinning matches up EU Member States with beneficiary countries, to help those countries acquire the necessary skills and experience to adopt, implement and enforce legislation based on EU laws. More on Twinning and the Ministry of Environmental Protection.

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20/10/2015 13:35
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