Questionnaire on the implementation of Directive 96/61/EC concerning
integrated pollution prevention and control (IPPC)
1. GENERAL DESCRIPTION
1.1. What are the main changes to national legislation and to the licensing
system that were necessary in order to meet the overall aim of achieving
integrated prevention and control of pollution arising from the activities
listed in Annex I to the Directive?
[NO CHANGES COMPARED TO PREVIOUS REPORTING (2003)] Finland has
enacted a general act on environmental pollution control, the Environmental
Protection Act (86/2000). This Act contains integrated provisions on the protection of
soil, water and air. The Act brought together provisions on environmental protection
that had previously been scattered in sectoral acts.
The same Act created an integrated environmental permit system, in which all
sectoral environmental impacts are assessed in a single permit procedure, by a single
competent authority. The municipal environmental committees, regional environment
centres and environmental permit authorities act as permit authorities in Finland. The
earlier Water Courts were abolished and environmental permit authorities were
established to replace them. The permits for the activities of the IPPC Directive are
processed either by the environmental permit authority or the regional environment
2. COVERAGE OF ACTIVITIES AND INSTALLATIONS
2.1. For each subheading in Annex I (1.1, 2.3(a), 6.4(b) etc.), how many
installations fall into the categories set out below:
See the attached Annex A.
all existing installations within the meaning of Article 2(4), in
operation at the end of the reporting period,
existing installations for which a substantial change was notified to
the competent authority and for which a permit was granted during
the reporting period,
new installations (including those not yet in operation) for which a
permit was granted during the reporting period.
In answering this question, it should be noted that the same installation could
carry out activities falling under different subheadings. All relevant activities
should be indicated (even if this means that the installation is counted more
than once). Since many chemical installations carry out more than one
activity as defined in the subheadings of heading 4, only the overall figures
for heading 4 should be given (i.e. no figures for individual subheadings).
2.2. What is the total number of IPPC installations at the end of the
A total of 666 installations.
In answering this question, care should be taken not to count the same
installation more than once, even if it carries out several Annex I activities.
3. BASIC OPERATOR OBLIGATIONS
3.1. What legally binding measures or administrative plans have been
established to ensure that the requirements referred to in Article 5(1)
are complied with by the end of the transition period mentioned therein?
[NO CHANGES] When filing a permit application, the operator is required to submit
to the permit authority all the information to ensure compliance with Article 3 of the
IPPC Directive in connection with deciding on issuing the permit and its conditions.
The provision of information has been ensured by issuing a detailed decree on the
necessary information. In addition, the permit authority is entitled to obtain from
operators other necessary information for the processing of the matter. The permit
issue cannot be resolved until the relevant information has been submitted to the
The assessment of existing installations takes place during a transition period. The
transfer of installations to the system provided for in the new legislation is subject to a
separate act (Act on Implementation of the Legislation on Environmental Protection
113/2000). This Act and the Environmental Protection Decree (169/2000) lay down
provisions on the timetable for the transfer of existing installations to the new system.
4. EXISTING INSTALLATIONS
4.1. What legally binding measures or administrative plans have been
established to ensure that the requirements referred to in Article 5(1)
are complied with by the end of the transition period mentioned therein?
[NO CHANGES] The requirements of Article 5(1) of the Directive apply to all
existing installations in accordance with a separate implementing act (Act on
Implementation of the Legislation on Environmental Protection 113/2000); see the
reply to 3.1. This implementing Act defines how and when existing installations must
apply for a permit that fulfils the requirements of the new legislation and, at the same
time, those of the IPPC Directive. All installations that require a permit must act in
accordance with the requirements of Article 5(1) by the date provided in the
Directive. Installations that have transferred to the new system are, therefore, subject
to the requirements of Article 5(1) of the Directive also before the transition period set
in the Directive ends.
5. PERMIT APPLICATIONS
5.1. How does national law ensure that permit applications contain all the
information required by Article 6?
All the information mentioned in Article 6 must be provided in the permit application.
The Environmental Protection Decree lays down provisions on the obligatory
information to be included in the application. If the permit application is incomplete
and it is not supplemented, it is rejected. Despite this decision, however, a new permit
can be applied for the activity, in which case the permit application must include the
necessary information or it is rejected again.
6. COORDINATION OF THE PERMITTING PROCEDURE AND CONDITIONS
6.1. Which competent authority or authorities are involved in permitting
[NO CHANGES] The permit is issued by a single competent authority. In Finland,
either the environmental permit authorities (3) or the regional environment centres
(13) are competent permit authorities for IPPC installations. Each permit authority
processes the environmental permit applications within its competence. The
competence of the authorities is provided by decree based on regional criteria and
criteria associated with the size of the installation. The permit authority has the
possibility to use the knowhow of other authorities by requesting their opinions in the
matter, etc. However, one competent permit authority always decides on issuing the
permit. The new legislation applies to all polluting activities and the estimated
number of installations that need a permit is approximately 30,000. Of these,
approximately 670 are IPPC installations and approximately 5,700 fall within the
competence of the State permit authorities.
6.2. How does national law ensure that the permitting procedure and
conditions are fully coordinated where more than one competent
authority is involved? How does this coordination work in practice?
[NO CHANGES] See the response to 6.1.
7. PERMIT CONDITIONS
7.1. Completeness of permit conditions
7.1.1. How does national law ensure that the permit contains all the requirements
specified in Article 9? In particular, give details on how each of the
following items is provided for:
National law is fully consistent with the requirements of the Directive. The
Environmental Protection Act (section 43) and Decree (sections 18–20a) include
provisions on all the requirements and permit regulations that must be included in the
environmental permit (see Annexes 1 and 2 at the end of this document). These
provisions include both obligatory and case-specific permit regulations. In addition,
both binding and indicative regulations on applicable limit values may be and have
been issued by Government decree.
Regulations for the purpose of preventing pollution, regulations pertaining to
fisheries, waste and waste management regulations, monitoring regulations,
regulations concerning emissions into a sewer, etc. shall be included in the
environmental permit (section 43 of the EPA, see Annexes 1 and 2).
limit values for emissions to air and water,
The provisions on limit values for emissions to air and water are included in section
43(1) of the Environmental Protection Act and in sections 18, 19(2) and 19(3) of the
Decree (Annexes 1 and 2). More detailed provisions on numerical limit values, etc.
have been issued by Government decrees (previously Government decisions). These
provisions are constantly being revised and the old provisions remain in force until
minimisation of long-distance or transboundary pollution,
[NO CHANGES] See likewise section 43 of the Environmental Protection Act and
section 19(4) of the Environmental Permit Decree (Annexes 1 and 2).
In addition to the implementation of the IPPC Directive, Finland is party to several
relevant international agreements.
protection of soil and groundwater,
[NO CHANGES] The regulations concerning the permit are included in the
Environmental Protection Act and Decree (Annexes 1 and 2).
The Environmental Protection Act also includes general soil and groundwater
pollution prohibitions. Waste or other substances shall not be left or discharged on the
ground or in the soil so as to result in such deterioration of soil quality as may
endanger or harm health or the environment, substantially impair the amenity of the
site or cause comparable violation of the public or private good (soil pollution
prohibition). A substance shall not be deposited in or energy conducted to a place or
handled in a way that:
1) groundwater may become hazardous to health or its quality otherwise materially
deteriorate in areas important to water supply or otherwise suitable for such use;
2) groundwater on the property of another may become hazardous to health or
otherwise unsuitable for usage; or
3) the said action may otherwise violate the public or private good by affecting the
quality of groundwater (groundwater pollution prohibition).
These prohibitions are unconditional and a permit cannot be issued contrary to such
prohibitions. Regardless of the permit, the operator shall also ensure that these
prohibitions are not violated. The violation of the prohibition is directly punishable
regardless of the permit issued.
[NO CHANGES] The regulations concerning the permit are included in the
Environmental Protection Act (sections 43 and 45) and Decree (Annexes 1 and 2).
efficient use of energy,
See section 43 of the Environmental Protection Act and section 19 of the Decree
(Annexes 1 and 2). Where necessary, the permit decision must also indicate how […]
measures and reporting based on energy-saving agreements have been taken into
account in setting the terms of the permit. Energy efficiency shall be taken into
account as needed in the permit regulations.
release monitoring requirements,
[NO CHANGES] As indicated above, the regulations concerning the permit are
included in the Environmental Protection Act and Decree (Annexes 1 and 2).
Operators are subject to the so-called knowledge requirement for their activity, which
means that they must have sufficient knowledge of their activities’ environmental
impact and risks and of ways to reduce harmful effects. This is particularly relevant
for self-monitoring. Provisions on the monitoring of the activity are particularly
included in section 46 of the EPA, according to which the operator shall monitor
emissions and report on them to the authority. The authority may base its reaction
directly on the monitoring report.
In accordance with section 46 of the EPA, the necessary regulations on operative
monitoring of the activity and monitoring of emissions, waste and waste management,
the impact of the activity and on the monitoring of the state of the environment
following the discontinuation of the activity must be issued in the permit. In addition,
the operator may be ordered to provide information necessary for monitoring. When
needed, the permit authority may order several permit holders to jointly monitor the
impact of their activities. The operator may be required to provide the permit
authority or an authority assigned by it with a monitoring plan in sufficient time so
that monitoring may be initiated when the activity begins or at some other time
appropriate with regard to the impact of the activity. Notwithstanding whether the
operator holds a valid permit, monitoring regulations and an approved monitoring
plan may be amended when needed. A decision may be amended ex officio or by
demand of the permit holder, supervisory authority, an authority protecting the public
good, local authority or a party suffering harm.
prevention of accidents and limitation of their consequences,
See section 43 of the Environmental Protection Act and sections 19 and 20 of the
Decree (Annexes 1 and 2).
measures relating to abnormal operating conditions,
[NO CHANGES] The regulations concerning the permit are included in the
Environmental Protection Act and Decree (Annexes 1 and 2).
site restoration upon definitive cessation of activities (requirement for
See section 43 of the Environmental Protection Act and sections 19 and 20 of the
Decree (Annexes 1 and 2).
special provisions for installations under subheading 6.6 of Annex I.
There are no special provisions in legislation, but section 1(11)(a) of the
Environmental Permit Decree states that the capacity or permit limit for these
activities is considerably lower than that required in the Directive. The possible
special conditions of the activity are taken into account in each case in the permit
7.2. Appropriateness and adequacy of permit conditions
7.2.1. What are the legislative provisions, procedures and criteria for setting
emission limit values and other permit conditions, ensuring that they lead to
a high level of protection for the environment as a whole? Have any specific
guidelines for competent authorities been issued? If so, provide information
on the type of guidelines issued.
The Environmental Protection Act and Decree and the Government decrees issued
under them ensure a high level of environmental protection. Government decrees
include detailed numerical limit values and indicative limit values that become a
binding limit value in the permit decision. Government decrees are constantly being
7.2.2. What kind of (binding or non-binding) guidance exists in Member States for
determining best available techniques?
No binding guidance has been issued in Finland for determining best available
techniques. In accordance with the Environmental Protection Act, the principle that
the best available technique shall be used applies to activities that pose a risk of
pollution (section 4 of the EPA). In addition, measures concerning the prevention and
limitation of emissions shall be based on the best available technology (section 43(3)
of the EPA).
Finland actively participates in the exchange of information organised by the
European Commission on best available techniques between countries and the various
industries and industrial activities. In Finland, the exchange of BAT information has
been agreed to take place in sectoral groups that will be set up, as necessary, to
prepare the BAT reference documents or BREFs. One half of the members are
representatives of the sector in question and the other half are permit authorities.
Currently these sectoral groups have about 300 members. Information on new BREFs
is provided through the sectoral groups and training is provided in seminars in the
sector, etc. Training is provided for the permit authorities (regional environment
centres and environmental permit authorities, municipal permit authorities, the
industry, engineering offices and consultancy firms, including the SME sector).
In addition to participating in the exchange of information on best available
techniques at the EU level, Finland carries out national BAT investigations for sectors
that are not included within the scope of the IPPC Directive but where such an
investigation is found necessary. A total of 22 national BAT reports have been
prepared so far and several are either being prepared or planned.
7.2.3. How, in general terms, is the information published by the Commission
pursuant to Article 16(2) or by international organisations taken into
account generally or in specific cases when determining best available
[NO CHANGES] The information published by the Commission pursuant to Article
16(2) and the so-called BAT reference documents or BREFs play a key role in
determining BATs. Even though these documents are not binding, they are relevant in
the BAT assessment of the permit decisions. A considerable number of both
authorities and operators are involved in BAT work in Finland (see the replies to 7.2.2
and 7.2.5), so knowledge of the content of the BREFs is good.
7.2.4. How useful, as a source of information for determining emission limit values,
equivalent parameters and technical measures based on the best available
techniques, is the information published by the Commission pursuant to
Article 16(2)? How could it be improved?
The level required in the BREFs is usually the basis for the permit consideration, but
there are many limitations to the use of the BREFs. As an example, it could be
mentioned that the drafting of the BREFs has taken a lot of time and the draft
documents cannot be referred to in the permit consideration. In addition, it has been
impossible to take into consideration all the individual characteristics of the
installations in the BREFs. The design of the environmental protection technique of
the installation with its guaranteed values may have been based, for example, on an
entirely different fuel than the fuel used in accordance with the current standards.
Noise abatement is excluded from nearly all BREFs.
7.2.5. What measures have been taken to ensure that the emission limit values and
the equivalent parameters and technical measures referred to in Article 9(3)
are based on the best available techniques, without prescribing the use of
any technique or specific technology, but taking into account the technical
characteristics of the installation, its geographical location, and the local
In accordance with section 43 of the Environmental Protection Act, when permit
regulations are issued, the nature of the activity, the properties of the area where the
impact of the activity shows, the impact of the activity on the environment as a whole,
the significance of measures intended to prevent pollution of the environment as a
whole and the technical and financial feasibility of these actions shall be taken into
account. Permit regulations concerning limit values for emissions and the prevention
and limitation of emissions shall be based on the best available technology. However,
the permit regulations shall not prescribe the use of one specific technique.
Section 37 of the Environmental Protection Act provides which factors shall be taken
into consideration in assessing the best available techniques (see Annex 3).
The national sectoral BAT groups have been a very good channel in providing BAT
information to permit authorities, operators, sectoral organisations, etc.
7.2.6. What kind of (binding or non-binding) guidance exists in Member States
concerning the release monitoring requirements to be included in the
The release monitoring requirements are based on the permit regulations issued
pursuant to the Environmental Protection Act and Decree (section 43 of the EPA).
The necessary regulations on operative monitoring of the activity and monitoring of
emissions, waste and waste management, the impact of the activity and on the
monitoring of the state of the environment following the discontinuation of the
activity must be issued in the permit. Monitoring can also be carried out in the form of
joint monitoring by several operators (section 46 of the EPA). The Environmental
Protection Act also lays down provisions on the quality assurance of measurements
and inspections (section 108 of the EPA). These measurements are made both by
operators (self-monitoring) and by authorities and, under their commission, by
consultants. Standards and measurement methods can also be set by Government
decree, particularly if they are of key importance to verify a numerically indicated
emission value or quality value, for example.
7.2.7. What is your experience regarding the interface between the permit
requirements under the IPPC Directive and the Directive establishing a
scheme for greenhouse gas emission allowance trading within the
Community and amending Council Directive 96/61/EC?
The Environmental Protection Act was amended so that emissions trading shall be
taken into account in the permits and the installations involved in it cannot be issued
emission limit values for the greenhouse gases referred to in the Emissions Trading
Act, unless they are necessary to ensure the prevention of local pollution (section
43(5) of the EPA). There have been no problems in practice.
Note: Member States are not required to give any answer to this question if
the Community greenhouse gas emissions trading scheme has not started by
1 January 2005 as planned.
7.3. Available representative data
7.3.1. Provide available representative data on the limit values laid down by
specific category of activities in accordance with Annex I and, if appropriate,
the best available techniques from which those values are derived. Describe
how these data have been chosen and collected.
The permit decisions pursuant to the IPPC Directive for the categories 2.2 and 3.1
reported here, which had been issued by the end of 2005 as follows, have been used in
category 2.2: permit for one installation (a total of 3 installations)
category 3.1: permit for three installations (a total of 7 installations)
Of these permits, a representative installation in terms of its technique and emission
limit values has been selected from each reported category by comparing the permit
regulations of the installations, on one hand, and by consulting expert permit
authorities, on the other hand. Information on the representative limit values has been
collected separately into Annex B.
The Commission may, before or during the reporting period, suggest
guidance for responding to this question.
7.3.2. What types of permit conditions other than emission limit values have been
set? In particular, give examples of:
Some typical examples of permit regulations issued in addition to emission limit
values are listed below. The list is non-exhaustive.
equivalent parameters and technical measures that supplement emission limit
values set in the permit,
- In the manufacture of cement and in the storage, transportation and other processing
of stone and products, it shall be ensured that the activity does not result in dusting so
as to cause harm to health in the surrounding habitation. The activity carried out in the
area shall aim at not exceeding the one-day concentration limit of 120µg/m3 for total
suspended particles and the one-day concentration limit of 70 µg/m3 for inhalable
particles in inhabited areas. Dusting shall be prevented by the location, paving,
cleaning and sprinkling of roads and driveways. The dusting of stone and product
storages and banking areas shall be prevented by location, covering, sprinkling and
protective stands. The height of stone and product storage piles may not exceed 10 m
in open piles located within 250 m of habitation and hospital areas.
Incineration of solvent-rich water
- On the basis of the application, solvent-rich water may be incinerated using cement
kilns 4 and 5. The incineration of solvent water in cement kilns requires that solvent
water clearly has a reducing impact on NOx emissions. If the use of solvent water to
reduce NOx emissions is discontinued, the installation shall find substituting water or
a water mixture to maintain the achieved NOx level. However, if the new technique
causes a deterioration in product quality or significant risks of equipment failure, the
technique may be abandoned.
- When incinerating recycled oil, the temperature of the flue gas from calcination shall
be raised in a controlled and homogeneous manner even in the most unfavourable
conditions for a minimum of two (2) seconds to 850 oC as measured in the vicinity of
the inside wall of the calcining kiln. The residence time, minimum temperature and
oxygen content of flue gases shall be verified at least once during the commissioning
of the plant and in the most unfavourable foreseen operating conditions.
- The utilisation rate of the dust filters in calcination shall be at least 98 per cent, as
calculated from the operating time of the calendar month. Also the utilisation rate of
other dust filters shall be recorded.
- Operators shall monitor the development of the industrial sector represented by them
and be adequately informed of the best available technique and prepare for the
introduction of such techniques.
equivalent parameters and technical measures that replace emission limit
Sulphur content of fuels
- The sulphur content of heavy fuel oil and recycled fuel used as fuels may not exceed
1 per cent of weight and the sulphur content of light fuel oil may not exceed 0.1 per
cent of weight.
conditions concerning the protection of soil and ground water, waste
management, efficient use of energy, release monitoring requirements,
prevention of accidents and limitation of their consequences, measures
relating to abnormal operating conditions and site restoration upon definitive
cessation of activities (conditions concerning the protection of soil and
ground water, as well as waste management, release monitoring requirements
and measures relating to abnormal operating conditions),
Protection of soil and ground water
- Waste, raw materials and fuels shall be kept and processed in the installation so that
they do not cause soil pollution, odours, the pollution of groundwater or water bodies
or the littering of the plant area or its surroundings.
- Hazardous waste shall be stored in a separate place that is guarded, covered and
equipped with a liquidproof base so that it cannot mix with each other or other waste
or spread to the surrounding soil, water body or groundwater even in leakage
situations and where it can be easily recovered in case of a leak.
- The operator is required to ensure that the activity does not result in such
deterioration of soil or groundwater quality as may endanger or harm health or the
environment. The pollution of soil or groundwater shall immediately be notified to the
Environment Centre of Southeast Finland and the environmental committee of the
city of Lappeenranta. The condition of soil in the area shall be investigated at the
latest following the cessation of the activity for eventual purification and landscaping.
- In all activity, it shall be ensured that as little waste as possible is generated. Waste
shall be sorted taking into consideration the recovery possibilities of the various
fractions and the possible need for separate dumping required by disposal. All
recoverable waste shall be reused by the installation itself or transported elsewhere for
recovery. Recovery shall aim at recovering primarily the material included in the
waste and secondarily the energy included in it. Recoverable cardboard and paper
shall be recycled and the collection of waste paper shall be arranged in office
facilities. Burnable plastic (not PVC) and wood-containing waste, as well as paper
waste that is not recycled, shall be recovered, where possible. Metal waste that is
suitable for scrap collection shall not be transported to a landfill site. In addition, any
provisions on waste recovery laid down in Lappeenranta pursuant to section 13 of the
Waste Act and the waste management regulations of the town shall be taken into
- The aim shall be to recover the electrostatical precipitator dust generated in the
installation. The operator shall be informed of the concentrations of harmful
substances in its process waste intended for landfilling or recovery and their
solubility. The heavy metal concentrations of electrostatical precipitator dust shall be
analysed and the analysis shall be carried out at least every three years and every time
there is an essential change to a raw material. In addition, an appropriate solubility
test of harmful substances shall be carried out for disposal purposes. If electrostatical
precipitator dust is intended to be used as agricultural liming material, its heavy metal
concentrations shall not exceed the maximum contents presented in Table 1 of Annex
2 to the Ministry of Agriculture and Forestry Decision 46/1994 on Certain Fertiliser
- Hazardous waste shall be transported appropriately packed and labelled into a lawful
processing facility every year, unless there is a special reason for a less frequent
processing interval. The chemical containers and packages considered as hazardous
waste shall be washed or otherwise made harmless before recovery or other use.
Cleaning waste that is unsuitable for the process shall be treated as hazardous waste.
However, the foregoing shall not apply to containers that are used again in a manner
corresponding with the earlier use or transported to a facility with a permit to receive
- Hazardous waste shall be packed for storage and transportation purposes into leak-
proof containers or vessels equipped with appropriate labels on the nature and
dangerousness of the hazardous waste. Hazardous waste shall not be mixed with each
other or other waste.
- Hazardous waste shall be transported to an undertaking or installation that is allowed
to receive such waste based on an environmental permit. A transfer document shall be
drawn up on the transportation of hazardous waste, including the details of e.g. the
possessor, transporter and recipient of hazardous waste, the time of transfer, the name
of the producer of the hazardous waste, the name, identification number, state and the
properties of the hazardous waste. The transfer document shall accompany the
transportation and it shall be given to the recipient of the hazardous waste.
Efficient use of energy
- Permit holders shall, in connection with the permit revision application, submit to
the environmental permit authority of Northern Finland for information the
documentation produced in the further analyses referred to in the energy-saving
agreement, as well as a reasoned action plan for developing the efficient use of
Usually the energy-saving agreement concluded by the installation has been
considered as adequate proof of energy efficiency having been taken into
consideration, and no special regulations have been issued on the efficient use of
Release monitoring requirements
- The contents of nitrogen oxides (NOx), carbon monoxide (CO), total particles and
sulphur dioxide (SO2) of the flue gases from cement kilns 4 and 5 shall be monitored
with continuous measuring equipment that automatically outputs the average values,
peak values and limit value exceedance times of these contents. When burning
recycled fuels in cement kiln 5, the contents of total organic carbon (TOC) and
hydrogen chloride (HCl) shall also be continuously monitored in a corresponding
manner. The calibration of continuous measuring methods shall be conducted at
adequate intervals with the help of an external expert. Dust emissions shall be
checked at least every three years. In addition, the temperature and the oxygen
content, pressure and temperature of flue gas shall be continuously measured in
cement kilns. The moisture content of flue gas shall be continuously measured, unless
the sampled flue gas is dried before analysing the emissions.
- When using the recycled fuel KPA-1, the heavy metals, dioxins, furans and
hydrogen fluoride (HF) of the flue gases from cement kilns shall be measured at least
once a year. The residence time, minimum temperature and oxygen content of flue
gases shall be appropriately verified at least once during the introduction of the
recycled fuel and in the most unfavourable foreseen operating conditions.
- All individual measurements shall be carried out by an impartial and competent
external measurer. All measurements shall be carried out in conditions that are fully
representative of the normal operating situation of the installation also for the raw
materials and fuels derived from waste that are fed into the process, so that the results
can be considered to be representative of the emissions. The first measurements shall
be carried out as soon as possible after the use of raw materials and fuels derived from
waste has become established. The measuring methods shall comply with the
requirements of Annex III to Government Decree 362/2003. The measurements and
reporting on the measurement results, as well as the comparison of the results with
limit values, shall also take into account the measurement requirements of the Decree
on the Incineration of Waste.
- The operation of the flue gas scrubber shall be monitored by measuring the pH of
removed water. The amount, temperature and acidity of the condensation water
removed from the scrubber shall be continuously measured and the total solids shall
be measured with daily samples from 1 January 2006 onwards. The quality of
removed condensation water shall be monitored for the pollutant parameters of
regulation 13 before 2006 twice a year during the first year of operation, after which
the monitoring frequency can be changed based on the results in a manner approved
by the Environment Centre of Southeast Finland.
- Continuous measuring equipment shall be kept operational by ensuring its regular
maintenance and calibration. The annual time usability of the measuring equipment
shall be at least 90% when no recycled fuels are burned in the kilns. When using
recycled fuels, the provisions of section 22 of Government Decree 362/2003 on the
Incineration of Waste regarding the comparison of the measurement results of the
emissions into air with limit values shall be followed. The reliability of continuous
measurements shall be ensured at regular intervals with comparative measurements
carried out by an external measurer, for which purpose the installation shall be
equipped with measurement sites and assemblies in accordance with the SFS
standard. A description of the measurement system and the quality assurance of
measurements shall be submitted in connection with the first annual report.
- The nitrogen oxide, sulphur dioxide and particle emissions of lime kilns shall be
measured at least anually. If the sulphur content of the coal burned in the kilns
exceeds 390 mg per one megajoule of energy (mg/MJ), the bonding of sulphur in the
process shall be checked with measurements at least annually.
- The particle emissions of the central filters of the installation in normal situations
shall be measured so that the emissions of each filter are checked at least once during
the measuring cycle that does not exceed three years.
- The total uncertainty of continuous particle content measurement at the limit value
concentration with a 95 per cent probability shall not exceed 100 per cent. The
uncertainty of the comparison method shall be considered in determining uncertainty.
- The operator shall participate in the joint monitoring of air quality and related
impact studies in the area with regard to the emissions of the installation. The
implementation and details of the monitoring shall be separately agreed upon. The
monitoring plan shall be submitted to the Environment Centre of Southeast Finland
Prevention of accidents and limitation of their consequences
- The plant shall prepare for accidents so that the plant area has an adequate amount of
absorptive material as well as container capacity and equipment in case of various
- The shielding pools of oil and chemical containers shall be drained of rainwater and
melt water and their sealing shall be regularly ensured. Cracks shall be immediately
- In all situations that have resulted in quantitatively or qualitatively abnormal
emissions into the environment, the permit holder shall immediately take appropriate
measures to minimise environmental damage and to prevent the recurrence of such
events. In addition, the permit holder shall be prepared to immediately undertake any
necessary investigations and specifications to establish the scope and impacts of the
- The plant rescue plan and the plan on activities in accidents and incidents shall be
kept up to date and the staff shall be kept informed of operating instructions through
regular training and exercises.
Abnormal operating conditions
- Malfunctions and abnormal situations that may present a risk of environmental
pollution shall immediately be notified to the Environment Centre of Southeast
Finland and the environmental committee of the city of Lappeenranta. Any observed
exceedances of permit conditions or abnormal situations that result in exceptional
emissions or waste shall be notified to the Environment Centre of Southeast Finland
not later than the first weekday following the exceedance.
Site restoration upon definitive cessation of activities
(Regulations have only be issued to landfill sites in connection with the actual
- After the cessation of the dumping activity in the landfill site, the site shall be
finished so that the migration of surface water into waste filling is adequately
prevented and the site is adapted to the environment in terms of its landscape. The site
closure plan shall be submitted to the Environment Centre of Southeast Finland for
approval nine (9) months before starting closure work. The environmental committee
of the city of Lappeenranta shall be consulted. The legislation in force at the time
shall be considered when drawing up the closure plan.
- The landfill site operator shall be responsible for the after-treatment of the landfill
site to be closed for a minimum of 30 years. During this period, the landfill site
operator shall ensure that the removal of the landfill site does not endanger or harm
health or the environment.
conditions relating to environmental management systems.
The possible environmental management system has been considered in the permit
consideration, but no special regulations have been issued on the matter.
8. GENERAL BINDING RULES
8.1. Does national law contain the possibility of laying down certain
requirements for certain categories of installations in general binding
rules instead of including them in individual permit conditions?
The obligations for installations are mainly issued individually in permit conditions.
However, it is possible to lay down certain requirements for certain categories of
installations in general binding rules by Government decree (section 12 of the EPA).
The Government may decide, for the purpose of implementing the environmental
protection requirements of Council Directive 1999/13/EC on the limitation of
emissions of volatile organic compounds due to the use of organic solvents in certain
activities and installations and of Directive 2001/80/EC of the European Parliament
and of the Council on the limitation of emissions of certain pollutants into the air from
large combustion plants, on a joint obligation for certain operators to reduce
emissions and on the detailed targeting of this obligation to each operator within a
particular sector, as well as on amending these obligations, where necessary. If the
Government has not issued the decree referred to in subsection 1, the operators’
obligations to reduce emissions shall be based on the Government decree
implementing the Directive.
If the Government decree differs from the environmental permit issued pursuant to
this Act, the Government decree shall be followed. A permit regulation may be
stricter than the Government decree, if it is necessary 1) for the purpose of meeting
the preconditions for granting a permit; 2) to ensure that environmental quality
requirements issued by Government decree are met; 3) to protect waters; or 4) to
comply with the best available technique if this is provided by the Government decree
implementing the European Community act (sections 51 and 56 of the EPA).
8.2. For which categories of installations have general binding rules been
established? What form do such rules take?
Currently, such a general binding rule for a category of installations has only been
issued for installations that burn waste. Directive 2000/76/EC of the European
Parliament and of the Council has been implemented by Government Decree
9. ENVIRONMENTAL QUALITY STANDARDS
9.1. How does national law address the need for additional measures in cases
where use of best available techniques is insufficient to satisfy an
environmental quality standard set out in or defined pursuant to
[NO CHANGES] As a condition for granting an environmental permit, an
environmental permit is granted for activities that meet the requirements of the
Environmental Protection Act and the Waste Act and those of the decrees issued
under them (section 41 of the EPA). This requirement also means that the
Government decree on the quality of the environment shall be observed in the permit
consideration. The quality standard of the environment is ensured particularly by
issuing permit regulations, either based on a decree or a case-by-case determination.
Therefore, the Act does not separately state, unlike Article 10 of the IPPC Directive,
that stricter measures than those of best available techniques shall be issued in the
permit, where an environmental quality standard requires this.
9.2. Have such cases arisen? If so, give examples of additional measures.
10. DEVELOPMENTS IN BEST AVAILABLE TECHNIQUES
10.1. What steps have been taken to ensure that competent authorities follow
or are informed of developments in best available techniques?
[NO CHANGES] It has been agreed that the exchange of BAT information will take
place in sectoral groups that will be set up, as necessary, to prepare the BREFs. One
half of the members are representatives of the sector in question and the other half are
permit authorities. Currently these sectoral groups have about 300 members.
Information on new BREFs is provided through the sectoral groups and training is
provided in seminars in the sector, etc. Training is provided for the permit authorities
(regional environment centres and environmental permit authorities, municipal permit
authorities, the industry, engineering offices and consultancy firms) (see also the
replies to 7.2.2 and 7.2.5).
11. CHANGES TO INSTALLATIONS
11.1. What are the legislative provisions, procedures and practice for dealing
with changes made by operators to installations?
[NO CHANGES] Provisions on the changes made by operators to installations are
also laid down in the Environmental Protection Act and Decree. Section 28(3) of the
Environmental Protection Act provides that a permit is required for any alteration of
an activity that increases emissions or the effects thereof or any other material
alteration of an activity for which a permit has already been granted. No permit is
required, however, if the alteration does not increase environmental impact or risks
and the alteration does not require revision of the permit.
With regard to procedures, the Environmental Protection Decree (section 14) lays
down provisions on the information provided by the operator to the permit authority if
existing activities are to be changed in a way which requires a permit application.
11.2. How do competent authorities decide whether a change in operation
may have consequences for the environment (Article 2(10)(a)), and/or
whether such a change may have significant negative effects on human
beings or the environment (Article 2(10)(b))?
[NO CHANGES] See the reply to 11.1; in other words, the determination is based on
each case. In practice, the competent authority carries out an inspection at the
installation in question, the valid permit is checked, monitoring reports are checked,
12. RECONSIDERATION AND UPDATING OF PERMIT CONDITIONS
12.1. What are the legislative provisions, procedures and practice concerning
reconsideration and updating of permit conditions by the competent
[NO CHANGES] As in the abovementioned Environmental Protection Act and
Decree. A permit is normally issued until further notice. Permits granted until further
notice must set the date by which an application for the review of permit regulations
must be made and specify any reports that must be submitted by that time (section 55
of the EPA). The authority that granted the permit processes the matter in the same
way as the permit application of a new installation was processed, as appropriate. In
addition, if provisions that are stricter than the regulations of a permit already granted
under the Environmental Protection Act or the Waste Act are issued by decree, these
provisions shall be observed, the permit notwithstanding (section 56 of the EPA). A
material alteration of the activity of the installation requires that the permit be
reviewed either entirely or for certain regulations.
12.2. Is the frequency of reconsideration and, where necessary, updating of
permit conditions specified in national law, or is this determined by
This is not specified in law, but it is determined in each individual case. In accordance
with the Environmental Protection Act, permits granted until further notice must set
the date by which an application for the review of permit regulations must be made
and specify any reports that must be submitted by that time, unless such a stipulation
is deemed manifestly unnecessary. For a special reason a stipulation on the review of
permit regulations may also be issued in a permit for a fixed period. The authority that
granted the permit shall process the matter in the same way as the permit application
was processed, as appropriate. In practice, all permits are reviewed every 5–10 years.
13. COMPLIANCE WITH PERMIT CONDITIONS
13.1. Describe in general terms the legislative provisions, procedures and
practice ensuring compliance with the permit requirements.
See the abovementioned Environmental Protection Act – a general act on
environmental pollution – and Decree. Procedures and practices include the
monitoring and control system. In addition, the Environmental Protection Act
includes an extensive right to take legal action (members of the public, organisations)
in certain exceptional situations for the purpose of investigating compliance with the
permit requirements. The Act also includes a penal provision (section 116).
13.2. Which legislative provisions, procedures and practice ensure that
operators regularly inform authorities of the results of release
monitoring, and without delay of any incident or accident significantly
affecting the environment?
The Environmental Protection Act and Decree include emission monitoring and
reporting obligations. Operators shall draw up a monitoring plan according to which
operative monitoring and the monitoring of emissions and their impacts are carried
out. Emissions are monitored both by the operator and by the authority. Monitoring
by the authority mainly controls the reliability of the monitoring organised by the
operator. Where necessary, the authority may also carry out its own investigations.
The Ministry of the Environment has issued official control guidelines in 2005.
13.3. How does national law give the competent authorities the right and/or
the obligation to carry out on-site inspections?
Under national law, competent authorities have both the right and the obligation to
carry out on-site inspections. Provisions are laid down in the Environmental
Protection Act (Chapter 13) and Decree (section 29).
13.4. What are the procedures and practice concerning regular on-site
inspections by competent authorities? If regular on-site inspections are
not carried out, how do competent authorities verify the information
provided by the operator?
In accordance with the Environmental Protection Act, the control authority shall,
where necessary, prepare an annual control plan. Through management by results, the
Ministry of the Environment has required the regional environment centres to prepare
an annual control plan. The plan shall include regular annual inspections for large
installations and inspections at slightly longer intervals for smaller installations.
The environmental permit provides for regular reporting. Large installations report on
their production, fuels and emissions monthly and smaller installations annually.
Environment centres inspect the reports and assess the state of environmental
protection: the inspection may give rise either to a request for further information, a
visit and an inspection at the installation or, if everything seems to be in order, to
approving the regular report. A report is prepared of all inspections and entered into
the environmental protection information system. Part of the report is entered into the
database: why was the inspection carried out (preparation of a permit or reporting
programme, exceedance of permit conditions, complaint by a member of the public or
regular inspection) and what was the result of the inspection (the inspection does not
give rise to measures, the operator will prepare an investigation or a plan, the
measures to be taken have been agreed upon or the matter will be reported to the
police for investigation). The Ministry of the Environment has issued official control
guidelines in 2005.
13.5. What sanctions or other measures are available in cases of non-
compliance with the permit conditions? Were such sanctions or other
measures applied during the reporting period? (If available, indicate
appropriate statistics, for example using a template given in a guidance
document for reporting under the recommendation providing for
minimum criteria for environmental inspections in the Member States.)
The Environmental Protection Act provides for a procedure for the rectification of a
violation or negligence. In addition, members of the public and organisations, for
example, have the right to take legal action (section 92 of the EPA). Procedures
include a prohibition, a request for rectification, rehabilitation or a duty to investigate.
The effect of the procedure may be intensified by threat of a fine. The police are
required to provide executive assistance (section 93 of the EPA) and if the activity
involves criminal action, the supervisory authority shall report it to the police for
preliminary investigation (section 94 of the EPA).
No relevant statistics are available for the reporting period.
14. INFORMATION AND PARTICIPATION OF THE PUBLIC
14.1. How does national law provide for information and participation of the
public in the permit procedure? What are the main changes to national
legislation and to the licensing system that were necessary in order to
meet the additional requirements introduced through Article 4 of the
Directive of the European Parliament and of the Council providing for
public participation in respect of the drawing up of certain plans and
programmes relating to the environment and amending Council
Directives 85/337/EEC and 96/61/EC?
Note: Member States are not required to give any answer to this question if
the Directive on public participation enters into effect later than 1 July 2005.
The principle of openness is a key principle guiding public administration in Finland.
The general act on openness (Act on the Openness of Government Activities
621/1999) lays down provisions on access to information in Finland. This Act also
applies to environmental matters. Nevertheless, the Environmental Protection Act
includes a special provision that related information on emissions, monitoring data
and environmental status data are not confidential, however (section 109 of the EPA).
As a general rule, all the information provided to the authorities is public.
The possibilities of the public to participate in the permit procedure are extensive. The
Constitution of Finland also highlights the public’s right to be involved in decisions
that concern the environment. This right is specified in the Environmental Protection
Act by provisions that apply to hearing procedures in the permit consideration phase
(section 37 of the EPA) and the possibility to appeal a decision made (section 97 of
the EPA). In addition to stakeholders and parties suffering harm, these rights are
guaranteed to certain organisations. In projects that require an environmental impact
assessment, the separate EIA Act applies to hearings with regard to the EIA.
The Directive did not bring any changes to participation rights, as national legislation
was already in line with the Directive in this respect. Section 50 was included in the
Environmental Protection Act to ensure that the activities are not in conflict with the
requirements of the Directive.
14.2. How is the information about applications, decisions, and the results of
release monitoring made available to the public? To what extent is the
Internet used for this purpose?
Information about the applications, decisions and the results of release monitoring is
made available to the public in accordance with the general administrative procedure
and the special regulation of environmental legislation.
In accordance with the Act on the Openness of Government Activities (621/1999), all
official information is public, as a general rule. In addition, the Environmental
Protection Act (section 109) provides that related information on emissions,
monitoring data and environmental status data are not confidential.
Permit applications shall be publicised pursuant to section 38 of the EPA. The permit
authority shall publicise permit applications by posting them for 30 days on the notice
boards of the relevant local authorities as is laid down in the Act on Public
Announcements (34/1925). Likewise, the regional environment centre and the
environmental permit authority shall post permit applications on their own notice
boards. The content of the notice is laid down in greater detail by decree. The posting
of the notice must be announced in at least one newspaper in general circulation in the
area affected by the activities, unless the matter is of minor importance or the
announcement is otherwise manifestly unnecessary. Stakeholders especially
concerned by the matter shall be notified separately. Otherwise, the provisions of the
acts relating to administrative procedures apply to the hearing and pending of an
In addition, section 16 of the EPD applies to the hearing. Permit applications shall be
made public once the matter has been examined in sufficient detail. The permit
authority may request additional information to supplement the application, and may
where necessary also arrange consultations.
The publication announcement in respect of a permit application must contain at least
the following information: 1) the name and contact details of the applicant; 2) a
description of the applicant’s activities; 3) the location of the activities; 4) information
on relevant discharges and waste; 5) information on the display of documents for
public inspection; 6) information on filing objections and opinions; 7) information on
public hearings, if any.
The application documents must be forwarded to the municipal authorities for public
display in the place mentioned in the publication announcement.
Decisions shall be publicised in accordance with the requirements provided in law.
Section 54 of the EPA: “Decisions must be delivered to applicants and to those who
have separately so requested, and to supervisory authorities and authorities protecting
the public good in the case. In addition, those who have made a complaint in the case
or who have separately requested to be notified and those who have been separately
informed of the permit application, shall be notified of the decision. When a letter of
complaint has been signed by several complainants, the decision or a notice of the
decision need only be sent to the first signatory of the complaint. A notice on the
decision must be published immediately in the municipality where the activity is
located, and in other municipalities where the impact of the activity may show. Also,
a notice on the decision must be published in at least one newspaper in general
circulation in the area affected by the activity, unless the matter is of minor
importance or its publication is otherwise manifestly unnecessary.”
In accordance with the Environmental Protection Act, applications shall be published
in newspapers and be available to the public for a necessary period of time.
Information on pending permit applications is found on the Internet pages of the
permit authorities, as well. Permit decisions are also public documents that are
available on the Internet pages of the permit authorities.
14.3. What measures have been taken to ensure that the public is aware of its
right to comment on the documents referred to in Article 15(1)?
This right is included in the Constitution, for example. Information has been provided
on the Environmental Protection Act and Decree at the time of their entry into force.
14.4. How much time is there for the public to comment on permit
applications before the competent authority reaches its decision?
The time for hearing is usually 30 days, but it can be extended in exceptional cases.
Also the requirement to process the matter with dispatch shall be considered when
setting the time limits (section 38 of the EPA, sections 16–17 of the EPD).
14.5. How do the authorities consider the comments of the public when taking
The Constitution of Finland guarantees everyone the right to be involved in decisions
that concern environmental matters. The permit authority must inspect the opinions
issued and complaints made in the matter. It shall also take into account legislative
provisions on the protection of the public and private good. The complaints and
opinions are taken into account in the permit consideration. In addition, a reasoned
reply shall be provided to them. However, a separate reply is not provided to each
complaint and opinion, but complaints and opinions are taken into consideration in
connection with drafting and justifying permit regulations. The applicant is requested
to provide a response to complaints and opinions. There is no research data on how
these complaints and opinions are reflected in the permit decisions. Members of the
public make complaints and issue opinions on approximately 38% of all permit
14.6. In what circumstances can members of the public lodge an appeal to
another authority or court against a permit?
Members of the public have a three-step appeal system in all environmental matters
(see figure). Appeals are not restricted in any way by a leave to appeal system, which
means that all decisions of the environmental permit authority can be appealed to an
administrative court. Administrative courts – the Administrative Court of Vaasa as the
first instance and the Supreme Administrative Court as the second instance – function
as an appellate level. Other authorities do not process appeals relating to the content
of environmental permit matters. Claims in other courts can be filed in criminal and
damages cases. Section 92 of the Environmental Protection Act lays down provisions
on the right to take legal action and lists the parties that have the right to appeal. In
practice, approximately 17% of all decisions have been appealed.
Figure. Authority and appeal organisation
Supreme Administrative Court
Administrative Court of Vaasa
Municipal environmental Regional environment Environmental permit
committee centres authorities
* Other environmental * Environmental permits * The most important
permits of regional importance environmental permits
* Certain matters under * Water pollution * Permits/mixed
the Water Act compensation projects under the
* Certain forms of * Situations referred to Water Act
compensation in section 29 of the * Applicants of REC
EPA permits or significant
* Water pollution
14.7. What influence have the restrictions laid down in Article 3(2) and (3) of
Directive 90/313/EEC had on access to information and public
participation in the permit procedure?
[NO CHANGES] In Finland, secrecy and the publicity of documents are regulated by
the Act on the Openness of Government Activities. This Act lays down provisions on
how and under which conditions documents can be kept secret. Secrecy provisions
have not proved that relevant in practice. According to the information obtained from
permit authorities, business secrets are only seldom requested to be kept secret.
Information on emissions, monitoring or environmental status are not confidential.
The basic rule is that the operator indicates in connection with making the application
to what extent it considers certain information to be secret. However, the authority
independently decides on confidentiality in each case based on a case-by-case
15. TRANSBOUNDARY COOPERATION
15.1. Does national law provide for transboundary information and
cooperation or is the subject being left to bilateral or multilateral
relations between Member States or to administrative practice?
[NO CHANGES] Should the environmental impact of activities referred to in the
Environmental Protection Act (IPPC installations, etc.) extend to other countries, they
shall be interpreted under this Act as comparable to impact in Finland, unless
otherwise dictated by an agreement made with the country concerned (section 110 of
the EPA). Because of this, the permit authority may be obligated to investigate
whether a project could have transboundary impacts of which the target country
should be informed. Provisions on transboundary impacts are also included in the EIA
agreement on transboundary impacts and in the Nordic environmental agreement. In
addition, related provisions are included in the bilateral border river agreements made
between Finland and its neighbouring countries (Finland-Sweden, Finland-Norway
15.2. How is it established in practice whether the operation of an installation
is likely to have significant negative effects on the environment of
another Member State?
[NO CHANGES] The abovementioned duty to investigate the spread of impacts
primarily belongs to the applicant who shall present information on the quality and
quantity of discharges and the environmental impacts of the project in the permit
application. If the activity referred to in the permit application may have negative
transboundary effects, the permit authority shall inform of the permit application and
provide the relevant supervisory authority of the target country with an opportunity to
issue an opinion on the matter. The authority of the target country shall be provided
with the necessary information on an eventual inspection and otherwise be kept
informed of the progress of the matter.
15.3. How does national legislation and/or practice ensure adequate access to
information and participation in the permit procedure of the public in
the Member State likely to be affected? Is such participation
supplemented by a right of appeal?
[NO CHANGES] See above. Participation includes the right of appeal.
16. RELATIONSHIP WITH OTHER COMMUNITY INSTRUMENTS
16.1. How do Member States view the effectiveness of the Directive, inter alia
in comparison with other Community environmental instruments?
[NO CHANGES] The IPPC Directive has proved effective. It is accurate in its
wording but sufficiently flexible so that Member States can reasonably implement the
requirements of the Directive at the national level.
16.2. What measures have been taken to ensure that implementation of the
Directive is coherent with the implementation of other Community
[NO CHANGES] In Finland, the preparation of national legislation is based on
extensive cooperation between various parties. The national implementation of
directives is often prepared in working groups in which the administration, operators
and non-governmental organisations are all represented. When a directive has been
transposed, the smoothness of national implementation is ensured with training and
guidance in which the same parties are involved. The availability and
comprehensiveness of information is ensured in this manner.
The Ministry of the Environment acts as the implementing ministry with regard to
environmental directives. Coherence in the implementation of the directives is
coordinated through this guidance and the abovementioned means.
17. GENERAL OBSERVATIONS
17.1. Are there any particular implementation issues that give rise to concerns
in your country? If so, please specify.
A considerable delay of the BREFs has been a problem for many sectors, as the
gradual permit regulation review system used in Finland required that all IPPC
installations file applications to the permit authority for processing by the end of
2004, and IPPC permits have already been issued in several sectors before publishing
the final BREF.
Section 43 of the Environmental Protection Act
Permit regulations for the purpose of preventing pollution
Permits shall contain necessary regulations on:
1) emissions, emission limit values, the prevention and limitation of emissions and the
location of the site of emission; (14 June 2002/506)
2) wastes and reduction of their generation and harmfulness;
3) action to be taken in case of a disturbance or in other exceptional situations;
4) measures to be taken after discontinuing activities, such as remediation of the area
and prevention of emissions; and
5) on other measures to prevent, reduce or evaluate pollution, the risk thereof and
harm caused by it.
If, with regard to activities other than industrial production or the generation of
energy, regulations based on paragraph 1 do not, due to the nature of the activity,
provide the means for sufficient prevention or reduction of harmful environmental
effects, necessary regulations concerning production volume, feed content or energy
may be issued in the permit.
When permit regulations are issued, the nature of the activity, the properties of the
area where the impact of the activity shows, the impact of the activity on the
environment as a whole, the significance of measures intended to prevent pollution of
the environment as a whole and the technical and financial feasibility of these actions
shall be taken into account. Permit regulations concerning emission limit values and
the prevention and limitation of emissions shall be based on the best available
technology. However, the permit regulations shall not prescribe the use of one
specific technique. In addition, energy efficiency and precautions, preventing
accidents and limiting their consequences shall be taken into account as needed.
(14 June 2002/506)
When permit regulations are issued for a combustion plant and gas turbine with a fuel
power of 50 megawatts or more, the possibility for cogeneration shall be taken into
account, if it is technically and financially feasible. This consideration shall be based
on the situation of the energy market and the distribution of energy. (15 November
If the activity falls under the scope of the Emissions Trading Act (683/2004),
emission limit values shall not be issued in the application for the greenhouse gas
emissions referred to in section 2 of the Emissions Trading Act, unless they are
necessary to ensure that there is no significant local pollution. (30 July 2004/684)
Section 18 of the Environmental Protection Decree
Content of the recital section of the permit decision
The recital section of the permit decision shall contain the following information, as
1) the name and contact details of the applicant;
2) the grounds of the permit application;
3) commencement of processing the application;
4) an account of existing permits relating to the activities and a description of the
planning situation in the area;
5) information on the condition and quality of the environment on the site of the
activities, and on places which will be affected by the activities;
6) a description of the activities and their extent;
7) key information on the activities, the processes employed, raw materials, fuels and
8) details of provision for monitoring the activities and their impacts;
9) details of discharges and waste caused by the activities;
10) details of the environmental impacts of the activities;
11) details of proposed environmental protection measures and on the recovery and
disposal of waste;
12) details of proposed risk assessment and accident prevention measures, action in
the event of accidents, and action during the malfunctioning of treatment facilities or
other interruptions to normal processes;
13) information on the processing of the application;
14) official opinions, objections and opinions from interested parties, responses and
their essential content;
15) details of any inspections which have been carried out.
Section 19 of the Environmental Protection Decree
Content of the decision section of the permit decision
The decision section of the permit decision shall contain information on:
1) the decision and how any requirements, any assessment report as referred to in the
Act on the Environmental Impact Assessment Procedure and any statements from the
other involved authorities have been taken into account;
2) the terms of the permit set both for ensuring fulfilment of the requirements for the
granting of a permit and to facilitate monitoring;
3) the provision governing discharges of substances and compounds referred to in
annex 2 of this Decree, if the amounts of discharges of such substances or compounds
pose a potential hazard to the environment;
4) the provisions governing significant discharges which will spread into the
environment beyond Finland’s borders;
5) the provisions governing measures to prevent environmental pollution relating to
the launch of operations, servicing and maintenance, accidents, temporary suspension
of operations or final discontinuation of operations;
6) the provisions governing the monitoring of operations and their environmental
impacts and those relating to the development and supervision of environmental
protection in respect of the operations;
7) any provisions relating to compensation for loss or damage;
8) the validity and review of the permit and the terms of the permit;
9) any order for enforcement of the decision irrespective of any possible appeal, plus
the placement of collateral in relation to said order;
10) the processing fee.
The permit decision and related terms and orders must include a statement of reasons.
The decision must also include the provisions applied.
Where necessary, the permit decision must also indicate how environmental
management systems or measures and reporting based on energy-saving agreements
have been taken into account in setting the terms of the permit. The decision must also
mention the provisions of section 56 of the Environmental Protection Act.
The decision must have attached to it the address to which any appeal may be sent, or
a notice indicating that the decision is not subject to appeal.
Section 20 of the Environmental Protection Decree
Terms of permits for landfill sites
In addition to what is provided in sections 18 and 19 above, permit decisions for
landfill sites must also include terms on:
1) the category of the landfill site;
2) construction and care of the site;
3) the quantities and types of waste approved for disposal at the site in accordance
with the list referred to in section 75(1) of the Waste Act; (10 January 2002/12)
4) supervision and monitoring of the site;
5) advance provision and procedures in the case of accidents;
6) decommissioning and aftercare of the site;
7) the length of the time the proprietor will be responsible for aftercare of the site.
In issuing the term referred to in paragraph 1, subparagraph 7 above, account must be
taken of potential danger or harm to health or the environment posed by the site for a
period of at least 30 years after the site has been decommissioned.
Section 20a of the Environmental Protection Decree (15 May 2003/363)
Terms of permits for the incineration of waste
In addition to what is provided in sections 18 and 19 above, environmental permits for
activities that fall under the scope of the Government Decree on the Incineration of
Waste must also include the following terms:
1) the wastes to be incinerated by categories of waste, as provided in the Annex to the
Ministry of the Environment Decree on the list of the most common wastes and of
hazardous wastes (1129/2001), and the maximum permissible incinerated amounts of
2) the maximum permissible incineration capacity of the installation;
3) emission limit values for the pollutants defined in the Government Decree on the
Incineration of Waste;
4) aspects relating to wastewater monitoring and at least the acidity, temperature and
flow of wastewater;
5) sampling and measuring methods to monitor emission limit values;
6) the recording and processing of measurement results and presenting them to the
Environmental permits for activities relating to the incineration of hazardous waste
shall also include terms on the minimum and maximum mass flow and calorific value
of hazardous waste, and the maximum amount of pollutants, such as polychlorated
biphenyls (PCB), pentachlorophenol (PCP), chlorine, fluorine, sulphur and heavy
metals, in hazardous waste.
Section 37 of the Environmental Protection Decree
Assessment of best available techniques
In assessing the best available techniques referred to in section 3, paragraph 1,
subparagraph 4 of the Environmental Protection Act, the following factors shall be
taken into consideration:
1) reduction of the quantity and harmful impact of waste;
2) the hazard level of employed substances and the scope for using less hazardous
3) the scope for recovery and reuse of substances used and waste generated in
4) the quality, quantity and impact of discharges;
5) the quality and consumption of raw materials used;
6) energy efficiency;
7) prevention of operational risks and the risks of accident, and damage limitation in
the event of an accident;
8) the time needed for introducing the best available techniques and the importance of
the planned time for launching operations, plus the costs and benefits of limiting and
9) all impacts on the environment;
10) all the methods in use on an industrial scale for production and for controlling
11) developments in technology and natural science;
12) information on best available techniques published by the Commission of the
European Communities or international bodies.