National Contact Point for Renewable Energy Sources

With an integrated permit, a single decision replaces the following decisions/permits:

• permit for the release of gas or particulate matter into the air;
• permit under the water legislation for the release of sewage into water or soil (including the specification of water intake conditions);
• waste generation permit (along with permits for waste recovery, neutralisation, transport and accumulation);
• noise emission permit;
• electromagnetic field emission permit.

Importantly, in the case of an integrated permit, each of the above stages should apply the most beneficial solutions from the perspective of the requirement to eliminate or limit emissions. The purpose is to reduce the administrative load on entrepreneurs and to ensure more effective environmental protection through the coordination of various aspects related to the planned project.

An integrated permit includes project environmental impact assessment, including aspects such as the protection of air, waters, soil, natural resources, waste management, noise etc. An integrated permit defines the conditions to be met during project implementation and operation stages in order to protect the environment and public health.

The permit is required for biomass plants of at least 50 MW and for biogas plants with a processing capacity of at least 100 t a day wherever the biogas production is the outcome of waste recovery or neutralisation based on anaerobic fermentation (the requirement also applies to a plant for neutralisation or recovery of fallen or slaughtered animals or animal by-products of a production capacity above 10 t a day).

An integrated permit application must take into account the following basic conditions defined for permit applications in Article 184 of the Environmental Law:

• identification and address or registered office of the system operator;
• identification of the main operator of the plant or the scope of responsibility of particular operators in charge of specific parts of the plant for plant operation in accordance with the environmental protection law;
• address of the site where the system operates;
• information on the legal title to the system;
• information on the type of system, equipment and technologies used and the technical characteristics of emission sources and locations;
• assessment of the technical condition of the system;
• information on the activity;
• description of the assumed system operation variants;
• a block (general) diagram together with the mass balance and the types of materials, raw materials and fuels used which are significant from the standpoint of environmental protection requirements;
• information on the energy used or produced by the system;
• emission size and source or location – current and proposed – during normal operation of the system and under abnormal conditions, such as in particular start-up and shutdown;
• the conditions and parameters characterising the operation of the plant – defining the moment of ending the start-up and the moment of starting the shutdown of the plant;
• information on planned periods of system operation under abnormal conditions;
• information on the existing or anticipated environmental impacts of emissions;results of measurements, where required, of emissions from the system;
• emission changes, if occurring after last permit was obtained for the system;
• proposed actions, including the specification of technical-, designed to prevent or reduce the emissions and, if the actions are to be implemented in the period for which the permit is to be issued – and the proposed completion date of such actions;
• proposed procedures for monitoring the technological processes relevant to environmental protection requirements, in particular the measurement or recording of emissions and the fire safety requirements in the case of a waste generation permit including waste collection or processing;
• the declared time and method of shutting down the system or a specific part thereof without any risks for the environment – if the system is planned to be shut down during the period for which the permit is to be issued;
• the declared total time of further operation of the system, if it affects the determination of the environmental protection requirements, and the declared method of documenting the time of such operation;
• the declared system commissioning date in the case referred to in Article 191a of the Environmental Law;
• the period for which the permit is to be issued.

Furthermore, the application contains:

• information regarding a system requiring an integrated permit (e.g. environmental impact, cross-border environmental impact, the forecast noise emissions, the forecast quantity, condition and composition of industrial sewage, the forecast quantity of the water to be used);
• justification for the proposed emission quantities;
• description of variants of the measures to prevent contaminants;
• copy of a cadastral map with outlined boundaries of the site where a limited use area must be established;
• initial report (containing for example information about the activity pursued on the project site, information on the activities pursued on the site of the plant in the past, if available; names of risk-causing substances that are used, produced or released by onsite facilities that require an integrated permit; information on soil, ground and groundwater contamination with risk-causing substances on the project site);
• a document confirming that the applicant is entitled to act in legal transactions, if the system operator is not a natural person;
• a summary of the application using non-specialist language.
• in the case of waste generation permit – a fire safety study meeting the requirements defined in Article 42(4b)(1) of the Waste Act;
• a fire safety study laying down the fire safety conditions for the system, facility or a part thereof or another waste management site which were agreed with the County (City) Chief of the State Fire Service, prepared by:

1. a fire safety expert within the meaning of chapter 2a of the Polish Fire Safety Act – if the province marshal (Polish: marszałek województwa) or the Regional Director for Environmental Protection (RDOŚ) is the competent authority,
2. the person referred to in Article 4(2a) of that Act – if the county administrator is the competent authority;

• certificate of no criminal record for a system manager:

1. with regard to crimes against the environment,
2. who is a natural person or, for a shareholder, commercial proxy, supervisory board member or director of a system manager, who is a legal person or an organisational unit without legal personality – with regard to the crimes referred to in Article 163, Article 164 or Article 168 in conjunction with Article 163(1) of the Polish Criminal Code of 6 June 1997 – in the case of a waste generation permit.

Once the investor files the application, the authority first reviews the formal sides of the application to check if it is complete and if it complies with the formal requirements. If any shortcomings are identified, the investor is required to remedy them.

After the formal review, the authority determines the emission conditions to be taken into account in the permit. They must not result in a breach of the emission threshold values. Importantly, emission conditions should assume that the investor will use of the best practices determined in the BAT conclusions. 

The BAT conclusions for waste processing are defined in the Commission Implementing Decision (EU) 2018/1147 of 10 August 2018.

The permit should be issued within 6 months after the application submission date.

The competent authority, depending on the type and scale of the installation, is either the county administrator (starosta) or the mayor of a city with county rights. In certain other cases, the competent authority may be the marshal of the voivodeship or the Regional Directorate for Environmental Protection.

An integrated permit is open-ended, unless the system operator requests a fixed term.

F = B × AV / TV

F – registration fee amount
B – base rate of the registration fee for a given facility type
AV –  maximum theoretical (attainable) value of the parameter characterising the scale of the activity pursued at the facility
TV –  threshold value of the parameter characterising the scale of the activity pursued at a facility of a given type

After receiving the decision, the applicant has 14 days to appeal against it to the Local Appeal Body (Samorządowe Kolegium Odwoławcze). Subsequent available remedies include a complaint to the Provincial Administrative Court and, as the next step, to the Supreme Administrative Court.

You can file the application online through the ePUAP service. We recommend that you contact the local county authorities (Polish: starostwo powiatowe) before applying to confirm if they process online applications.