Background to this
The Swedish Environmental Protection Agency has previously produced a guide, which is primarily aimed at supervisory authorities, to guide any reconsideration or revocation of permits, which can be read more about here.
During the autumn and winter half of 2023, Sigholm, on behalf of the industry organization Avfall Sverige, produced a guide for operators with environmental permits in the energy industry to make the strategic choices on their own about whether the planned change fits within the existing permit or not. The purpose of the guidance is to guide if or when environmentally hazardous activities with older environmental permits need to be reviewed.
Clear guidance for a smoother process
The aim was to make it easier for businesses that want to change, expand or rebuild and that they should be able to use the guidance to identify where and how the limits for reviewing environmental permits look like and when and how it should be done. A large part of the assignment was about clarifying and gathering the overall picture of the process. An important part of the methodology used by Sigholm included interviews with various expert roles in their respective fields such as supervisory authority, lawyer and operator.
The importance of good dialog
Something that emerged from the interviews, but also from Sigholm's external monitoring of the subject, is that both the supervisory authority and the operator see a good dialogue as very important for a good and efficient management process. The guide has been developed for Avfall Sverige's members, but is of course relevant to anyone with an environmental permit and can be found via this link: https://www.avfallsverige.se/rapporter-utveckling/rapporter/2024-07-miljotillstand-gransdragningar-vid-omprovning/