PRTR reporting

Who should submit a PRTR report?

EPA-Licensed facilities

There is an obligation on all EPA-licensed facilities, and on operators in certain other industrial sectors, to make returns, in the form and content specified by the EPA, of their annual Releases (emissions) and Off-Site Waste Transfers for each calendar year by 31 March of the following year in accordance with the PRTR Regulations S.I. No. 123 of 2007 &  S.I. No. 649 of 2011 concerning the establishment of a European Pollutant Release and Transfer Register.


Non EPA-Licensed facilities
 
The PRTR Regulations apply to a number of non EPA-licensed activity sectors. In the Irish context, these sectors, and the applicable capacity thresholds above which facilities must report under PRTR Regulations, are:   

Sector Capacity Threshold
(PRTR Regulations Annex I)
Opencast mining and quarrying where the area effectively under extractive operation above 25 ha [1]
Urban waste-water treatment plants (prior to licensing under S.I. 684 of 2007) plants with a capacity of 100,000 population equivalents
Intensive aquaculture With a production capacity of 1,000 tonnes of fish or shellfish per year
Installations for the building of, and painting or removal of paint from ships With a capacity for ships 100 m long

[1] The term “Surface area effectively under extractive operation” means the surface of the area of the site reduced by the surface of the rehabilitated area and by the area of future excavation. Note that all in-site transport, processing, storage and associated facilities, including settlement lagoons, are to be included within this definition. (Source:  EU PRTR Guidance Document May 2006).

The same reporting requirements apply to the operators of non EPA-licensed facilities falling under the PRTR Regulations. Reporting for the calendar year is required to be completed by 31 March of the following year.

What should be reported under PRTR?

All releases to air, water and land of any pollutant specified in Annex II of the E-PRTR regulations for which the applicable threshold value specified in Annex II is exceeded and all off-site transfers of waste**. For off-site transfers of waste the threshold values are 2 tonnes per year for hazardous waste* and 2,000 tonnes per year for non-hazardous waste.

*The relevant weight is the (normal) wet weight of the waste.

**where an off-site transfer of waste means the movement beyond the boundaries of a facility of waste destined for disposal or recovery.

All pollutants listed in Annex II that are relevant to the processes operated at that facility and that might therefore occur in the facility’s releases and off-site transfers of waste water should be considered. This consideration is not limited to those pollutants that are listed in the facility’s permit/licence.

An activity is usually related to a typical pollutant release spectrum. Appendices 4 and 5 (indicative sector specific sub-list of pollutants) of the Guidance Document for the implementation of the European PRTR contain two tables which give operators and competent authorities an example of the pollutants which may be released in the performance of a specified E-PRTR-relevant activity. These tables are indicative only and should not be interpreted as a standard list of parameters for specific sub-sectors.

To decide which parameters are relevant to each specific installation, Appendices 4 and 5 should be referred to together with information contained in Environmental Impact Assessments (EIAs), permit applications, site inspection reports, process flow sheets, material balances, read-across of similar operations elsewhere, engineering judgements, published and peer-reviewed literature and the results of previous measurement exercises. As a result, it might be that for a certain activity fewer or possibly more pollutants than indicated have to be considered.

If an activity specified in Annex I to the E-PRTR Regulation is carried out and the capacity threshold specified therein is exceeded, there is an obligation to report releases and off-site transfers as specified in Article 5 of the E-PRTR Regulation.

When do I need to report my PRTR data?

There is an obligation on all EPA-licensed facilities, and on operators in certain other industrial sectors, to make returns, in the form and content specified by the EPA, of their annual Releases (emissions) and Off-Site Waste Transfers for each calendar year by 31 March of the following year.

Waste Water Discharge Licenced Facilities should report their annual Releases (emissions) and Off-Site Waste Transfers for each calendar year by the 28th February of the following year.

Where do I submit/upload my PRTR workbook?

The completed PRTR excel workbook should be converted to xml format (see FAQ on how to convert PRTR workbook to xml) and should then be uploaded to the AER/PRTR reporting website using your Username and Password which are provided to you in the reporting reminder email sent by aerreturns@epa.ie in February of each year.  

Why do I have to report AER & PRTR (Legal Obligations)?

The legal basis for the annual environmental reporting obligations applying to both EPA-licensed and non EPA-licensed industrial and waste management facilities annual environmental returns are as follows:
 
PRTR Regulations

The PRTR Regulations are the European Communities (European Pollutant Release and Transfer Register) Regulation 2007, S.I. No. 123 of 2007, E-PRTR Regulation, (EC) No 166/2006 and the S.I. No. 649 of 2011, concerning the establishment of a European Pollutant Release and Transfer Register.

As set out in the PRTR Regulations, releases of pollutants and off-site transfers of waste by facilities operating in relevant industrial sectors will be reported by the EPA to the European E-PRTR website where the facility exceeds specified thresholds for the Capacity of the activity (Annex I of the PRTR Regulations) and for the quantities of the emissions (Annex II of the PRTR Regulations) and/or waste transfers (Article 5 1 (b) of the PRTR Regulations) from the facility. Following the coming into force of the PRTR Regulations on 22 March 2007 & 13 December 2011, there is now an obligation on all EPA-licensed facilities, and on operators in certain other industrial sectors, to make returns, in the form and content specified by the EPA, of their annual Releases (emissions) and Off-Site Waste Transfers for each calendar year by 31 March of the following year. 
 
Non EPA-Licensed facilities
 
The PRTR Regulations apply to a number of non EPA-licensed activity sectors. Please see FAQ "Who should submit a PRTR report?". The same reporting requirements apply to the operators of non EPA-licensed facilities falling under the PRTR Regulations. Reporting for the calendar year is required to be completed by 31 March of the following year.

 

EPA Licensing:  Annual environmental information reporting requirements

The requirements for reporting of Annual Environmental Information arise under individual EPA licences issued under the EPA Acts 1992 – 2008, the Waste Management Acts 1996 – 2008, the Waste Water Discharge (Authorisation) Regulations S.I. 684 of 2007 and other legislation.
 
The Annual Environmental Report (AER) is a standard requirement of all IPC/IE/Waste/Wastewater Discharge licences issued by the EPA. The content of the AER should give a concise summary of the environmental performance of the site for the reporting year as well as a record of on-going improvements on the licensed site. A key component of the AER is the Summary of Emissions and Waste Transfers, which is the information directly relevant to the PRTR Regulations.
 
The content and subject matter of the AER is specified in the relevant Schedule of your Licence. The EPA Guidance Note on the Annual Environmental Report provides guidance for compiling all of the necessary information on emissions, waste transfers and environmental performance of the facility for the purposes of compiling a suitable AER.

How do I include a copy of my PRTR workbook in my AER pdf (merge pdf files)?

Currently, a copy of the completed PRTR workbook must be attached to the AER. Only sheets of the PRTR workbook that contain data must be submitted (do not include the reference sheets of the workbook in the pdf). Each sheet of the PRTR Workbook contains a button marked “Print This Sheet”. This button will automatically sort the print lay-out of the sheet. When you press “Print This Sheet” you can print directly to a PDF or a paper copy that can be scanned later. If you do not use this button the lay-out of the sheets will not automatically be adjusted for printing. Note: You must press the “Print this Sheet” button on all sheets of the PRTR workbook that contain relevant data. Save each sheet prior to conversion to pdf. Click and hold on CTRL on your keyboard and select all the sheets in the PRTR Workbook for conversion to pdf. Choose save as pdf file or print to pdf.

To facilitate the creation of a PDF file from an Office or other document you will need access to Adobe Acrobat. You will also need Adobe Acrobat X Pro or similar to merge files e.g. merging the Main AER with appendices and the PRTR workbook

An alternative to merging files through Adobe Acrobat is to scan a paper copy of the complete AER. If you do this, you must ensure that the scan is of high quality and legible and that pages and content are upright for viewing on the website.

Please consult with the Procedure for creating and submitting the Full PDF AER for further information and guidance.

Where can I find my login details for PRTR/AER reporting?

Your login details for the AER/PRTR reporting website are sent in a reminder email from the helpdesk email aerreturns@epa.ie every February. If you did not receive or cannot find your login details please contact the helpdesk contact email aerreturns@epa.ie and they will be sent to you.

 

How do I create an xml file from my PRTR excel workbook?

On the first page of the excel PRTR workbook there is a grey button  called “Create AER XML Return & Upload”. When you click on this button it will take you through the process of creating and uploading the xml file. This process includes a series of validation checks and error notifications if you have omitted data or entered data which is significantly different to the previous year. Where the messages request that you check your data or enter an explanation for differences please verify data is correct and enter explanation in the "User feedback/comments" section on the "Facility ID & Activities" tab of the workbook to assist in validation checks.

How do I enable macros in my PRTR workbook?

Download the AER / PRTR Electronic Reporting Workbook by clicking on the Download Excel Template option and save it to your computer. Please select the "Enable Macros" option when opening the Workbook, to ensure that the Workbook will accept the information you enter correctly.

When you download the PRTR workbook you must save the workbook before opening it. This will ensure the workbook is saved in the correct format. You can then proceed to open the workbook. Make sure that macros have been enabled in Excel before filling out the PRTR workbook. When saving the PRTR workbook as you are completing it use the "Save" button. If you do select "Save As" make sure you save the PRTR workbook as "Excel 97-2003 workbook" (for Office 2007 and higher).

If you are not prompted to select the "Enable Macros" option when opening the Workbook, you will need to Enable the Macros in your Microsoft Excel software package on your PC. For further information, please refer to the appropriate "Enabling Macros" document for your particular version of Excel.There is guidance available on Enabling macros in Excel 2007 and Enabling macros in Excel 2002 & 2003.

 

How do I change the waste information on the "treatment and transfers of waste" tab of the PRTR?

On the "treatment and transfers of waste" tab of the PRTR workbook the waste information populates from the previous years data leaving only the tonnage section blank in your newly downloaded workbook. If you need to change an address or waste destination from the previous years details first delete the entire row using the grey "delete row" button in the workbook. To do this select a row by double clicking on the pollutant name (Column B) of the row you are trying to delete and then click the "delete row" button. You should then add a new row by clicking the "Add row" button and complete the new information in this row.

Who is responsible for the quality of the PRTR data?/Why does the EPA validate the PRTR data?

Who is responsible for the quality of the data?

Operators of PRTR facilities are responsible for the quality of the information that they report. They should report all required information to the EPA and before submitting the data, the operator should ensure an appropriate quality of the data by ensuring that the information is complete, consistent and credible. Operators are obliged to keep records of the data from which the reported information was derived and a description of the methodology use for data gathering for a period of five years.  The EPA Act (Article 13 (5) (c) of the EPA Act 1992 – 2008) also requires that information submitted by licensed facilities shall not be false or misleading.

Why does the EPA validate the data?

The EPA is obliged under the PRTR Regulations to assess the quality of the data submitted by operators, in particular as to their completeness, consistency and reliability (Article 9 of the E-PRTR Regulation).  Equally, the EPA Act (Article 13 (5) (c) of the EPA Act 1992 – 2008) requires that information submitted by licensed facilities shall not be false or misleading. Moreover, the EPA is responsible for the development of inventories of emissions to the environment and requires that the data collected for these purposes is of a sufficient quality and reliability.
 
All information submitted is therefore subject to a process of validation and verification by the EPA. For example, errors in or omissions from PRTR submissions might subsequently be detected during the EPA’s review of the information, during on-site audits of your facility or by yourself; this may necessitate correcting and resubmitting the information.
 
We strongly recommend that you retain all electronic and paper copies of your submissions and all related documentation in a secure location, as these may be required for inspection by either by your inspector or another authorised person.
 
Any errors or omissions will require to be rectified by the submission of corrected information by the facility operator.

What is the difference between the AER and PRTR? Do I have to submit both?

The PRTR is the reporting of emissions and waste transfers information via the EPA's PRTR workbook which is downloaded from the AER/PRTR reporting website. This is task 1 which must be performed for your annual reporting.

The Annual Environmental Report (AER) is a standard requirement of all IPC / IPPC licences issued by the EPA. The AER is a single report by a licensee on their facility’s environmental performance in the previous calendar year. The pages of the PRTR workbook that contain emissions and waste data should be included in the AER document as an appendix. The AER should be uploaded as task 3 on the reporting website. There is no longer a requirement to submit a hardcopy of the AER document.