Annual Environmental Report Contents Ireland
What goes in an annual environmental report in Ireland?
In Ireland, an Annual Environmental Report (AER) is a yearly public report that EPA licence holders submit. It covers the facility's activities, its environmental goals and how they are progressing, energy and water use, complaints and incidents, a summary of emissions monitoring, waste figures and financial provision. If you hold an Industrial Emissions (IE), IPC or waste licence, you must use the EPA's standard template. Submit it on the EDEN portal by 31 March each year, as a Licensee Return with document type "Annual Environmental Report" and subtype "AER". Urban waste water discharge licence holders have their own guidance and a 28 February deadline (EPA AER page).
Approach: I couldn't search the EPA licence register or the Irish PRTR returns this time, so this is based on the EPA's AER web page and its Guidance Note for Completing the AER for IE, IPC and Waste Licensed Facilities (Version 4.0, December 2021) (PDF).
Which licences use the template
- The template became mandatory for IE, IPC and waste licences from 2020 reporting onwards. The intensive agriculture sector is the exception and keeps its own template (p.3).
- Urban waste water and dumping-at-sea permit holders have separate AER guidance (EPA AER page).
Sections in the IE/IPC/waste template (Guidance Note v4.0)
| Section | What goes in it |
|---|---|
| Cover page and Declaration | Reporting year and licence details. The author gives their name and position and ticks the declaration, confirming the information is accurate and that the monitoring and Environmental Performance Reporting (EPR) data the licence requires have been submitted (p.4). |
| Introduction (max 250 words) | Main and secondary activities; overview of compliance (incidents, complaints); changes and upgrades to infrastructure; production increases or decreases; changes to the licence; certifications or awards; other environmental improvements (p.5). |
| Contact Us | Where the public can find out about the site's environmental performance, as the licence's communications programme requires. No personal data: the EPA will reject reports that contain it (p.5). |
| How we Manage our Facility | Table of environmental goals from your environmental management system, with target date and progress status (Complete / On track / Ahead of schedule / Not commenced / Delayed) (p.6). |
| Beyond Compliance (optional) | Projects that go beyond what the licence requires, plus an optional 250-word case study in Appendix III (p.7). |
| Energy & Water | Energy used and energy generated, in GJ, with % change on the previous year. Water use in m³ by source: groundwater, surface water, public supply, rainwater, recycled (pp.8-9). |
| Environmental Complaints | Number received and number closed, by type: odour, water quality, air quality, noise, waste, litter, vermin, soil contamination, vibration, other (p.10). |
| Environmental Incidents | Number of incidents by category (e.g. emission limit breach, fire, spillage, trigger level breach, uncontrolled release) and by severity, from Minor to Catastrophic (p.11). |
| Our Environmental Emissions | One line per parameter, not per emission point. For storm water, waste water and air, give the number of samples you actually took (excluding EPA samples) and the % that complied with emission limits or trigger levels. A trigger-level breach counts as a reportable incident (pp.12-15). |
| Odour | Number of odour assessments by the licence holder and by the EPA, and % compliant (p.16). |
| Fugitive solvent emissions | Every licensee answers Y/N. If it applies: solvents used (kg), % fugitive emissions, and whether this complied with IED Annex VII (p.17). |
| Groundwater | Whether you have a monitoring programme; whether the last 5 years of results show pollution; pollutants with increasing trends; investigations and actions taken (p.18). |
| Noise | Monitoring dates and locations (site boundary and/or noise-sensitive locations); whether you complied with limits, and what you did about any exceedances (p.19). |
| Waste | Waste generated, and waste accepted if any (hazardous, non-hazardous, inert): tonnes, % change on the previous year, and % recovery (pp.20-21). |
| Financial Provision | Whether you are in one of the 8 high-risk categories that need an EPA-agreed financial provision (e.g. landfills, Seveso sites, incinerators). The year the EPA last agreed your Closure, Restoration and Aftercare Management Plan (CRAMP) and your Environmental Liability Assessment Report (ELRA), and whether the site has changed significantly since (pp.22-23). |
Practical points from the guidance
- The AER is published on the EPA website. It is written for the public in plain English, following NALA guidelines, with word limits on comment boxes (pp.3-4).
- Reports that leave out data without enough explanation "may be rejected" (p.4).
- The template may not cover every AER requirement in your licence. Anything it leaves out "shall be submitted annually as a separate licensee return on the EDEN portal" (p.3).
- The AER is separate from Environmental Performance Reporting (EPR). EPR covers the PRTR and Large Combustion Plant reporting requirements and must be completed separately (p.3).
If you give me your sector or licence type (e.g. urban waste water or intensive agriculture), I can go through that sector's AER guidance.