“Environmental permit” is a term business owners use every day, but no document by that name exists in the legislation. It refers to one of two documents issued by the State Environmental Service. Which one applies to your company depends on the amount of pollution it generates.
The law On Pollution divides polluting activities into category A, B or C on the principle that the greater the pollution, the stricter the requirements. Category A and B companies receive a polluting activity permit, while category C companies are not issued a permit. Instead, the activity is entered in a register and a category C certificate is issued for it.
What categories A, B and C mean
Category A
Category A covers companies with the highest pollution, whose impact on air, water and soil reaches far beyond their own site, which is why the requirements here are the strictest. It includes large cogeneration plants, oil refining, metallurgy and other activities listed in Annex 1 of the law “On Pollution”.
For a category A company, it is not enough for emissions to stay within the limits, because it must also use technology that matches the best available in the industry, which the European Union compiles separately for each sector. In the category A permit, the State Environmental Service specifies how much each emission source may release and how often it must be measured.
The state fee for issuing a category A permit is currently 853.72 euros.
Category B
Category B covers companies with medium pollution, whose impact usually does not extend beyond the immediate surroundings of the site, but a permit must still be obtained before starting operations, just as in category A. It includes metalworking and woodworking plants, medium-sized boiler houses and other activities listed in Annex 1 of Cabinet Regulation No. 1082.
To obtain a category B permit, the company submits an application to the State Environmental Service with a description of the production process and emissions, based on which the State Environmental Service sets the permit conditions.
The state fee for issuing a category B permit is currently 362.83 euros.
Category C
Category C covers companies with small but regular pollution, which the state needs to know the source of. It includes car repair shops, small boiler houses and other activities listed in Annex 2 of Cabinet Regulation No. 1082.
No permit is issued for such an activity. Instead, the State Environmental Service enters the activity in the register and issues a certificate stating what the company must record and report from then on. These are usually annual reports on air pollution or generated waste, but in this case nobody assesses the technology itself.
There is no state fee for category C registration.
| Category | Pollution | Document | State fee |
| A | Highest | Permit | 853.72 euros |
| B | Medium | Permit | 362.83 euros |
| C | Low | Registration certificate | None |
The fee amounts are set by Cabinet Regulation No. 666 and they change from time to time, so it is worth checking the amount in the regulation before paying.
How to find out your category?
The category is determined not by the industry but by volume and capacity. A good example is a fuel station, which falls into category C with up to 2,000 cubic metres of fuel pumped per year, but above this threshold it is already category B.
The thresholds for each activity are set out in the law “On Pollution” and Cabinet Regulation No. 1082. If it is not clear from them which category an installation falls into, the information can be submitted to the State Environmental Service, which issues an opinion on the category within 14 days.
Two things that cost companies the most:
- If several polluting activities of different categories take place at one site, the company submits a single application for all of them, but the requirements are set by the strictest category. For example, if the workshop falls into category C but the boiler house into category B, the whole site needs a category B permit.
- In all three categories, the permit or certificate must be obtained before starting the activity, not alongside it.
What environmental documents must be attached to the application
The application is rarely the only environmental document the State Environmental Service expects.
Depending on the type of activity, the following materials may also be required:
- Draft emission limits for air pollutants
- Technical regulations issued by the State Environmental Service, if the activity is covered by them
- Noise assessment, if the site is located near residential buildings
- Water resource use permit, if the company extracts groundwater or surface water
- Environmental impact assessment report and the opinion of the Environment State Bureau
Which of them are needed depends on the type of activity and the location of the site.
How to apply and what to submit?
Both SES permits and category C registration can be applied for electronically in the State Environmental Service information system TULPE. The difference lies in the content of the application: for categories A and B it requires a full description of the production process, while for category C it is shorter.
Category A and B permit
In the application, the company describes the entire production process, specifying:
- the raw materials used and their storage
- all emission sources
- water and energy consumption
- the waste generated and its management
- the planned monitoring
In some cases, the application is also put out for public consultation, which extends the process by several weeks.
The most common reason an application is not accepted is a mismatch between the volumes stated in it and the construction or territorial planning documents, so it is worth comparing them before submitting.
Category C registration
The application is shorter and nobody assesses the technology, but two deadlines must be observed. The application must be submitted at least 30 days before starting the activity, and the State Environmental Service registers the activity within 14 days of accepting the application.
Three more things that differ here from a permit:
- Registration applies to a specific address, so a company with production sites in two different locations needs two registrations.
- The State Environmental Service publishes the registration information on its website and sends it to the municipality, so it is publicly available.
- If the activity changes significantly, the registration must be amended, and if the volume grows, the activity may already fall into category B, which means a new application and a state fee.
When is an EIA or SEA also required?
An EIA, or environmental impact assessment, is a procedure that must be carried out before obtaining a permit for activities that may significantly affect the environment. During it, the company prepares a report on the planned activity, after which the Environment State Bureau issues an opinion on it. This opinion is attached to the application, because without it the State Environmental Service will not issue a permit.
SEA, or strategic environmental assessment, applies not to an installation but to a planning document, such as a territorial plan, local plan or sectoral development plan. It becomes relevant for a company when the territorial plan for the chosen location provides for a different use than the project requires, so the municipality first has to amend or change the plan.
Both procedures include a public consultation. You can see how they are progressing in the announcements section.
Which environmental reports must be submitted every year?
Receiving the permit or certificate is not the end of the process, because once the activity starts, annual environmental reporting begins too, and its scope is set by the conditions of the document.
- Statistical reports No. 2-Air, No. 2-Water and No. 3-Waste must be submitted by 1 March for the previous year, filling them in in the LEGMC system.
- The NRT, or natural resources tax, return is submitted to the State Revenue Service by the 20th of the month following the quarter, while companies that pay the tax only for category C pollution submit it once a year by 20 January. The deadlines are set by Section 27 of the Natural Resources Tax Law.
- The waste report is based on records that must be kept throughout the year, so it cannot be put off until the report is being prepared.
- A chemicals report must be prepared by companies that use or sell chemical substances and mixtures in their operations.
If the document requires environmental monitoring, samples must be submitted to an accredited laboratory, because the permit conditions usually require the testing to be done by an accredited laboratory. For this work, we recommend the laboratory services of our partner SIA “Vides Audits”.
When is it worth bringing in environmental experts?
A company can handle part of this process itself, especially category C registration, but in more complex cases with several emission sources, a public consultation or a required emission limits project, preparing the application calls for industry knowledge.
SIA “Vides Konsultāciju Birojs” has been working with polluting activity permits since 1996. VKB environmental experts prepare applications for all three categories, carry out the necessary assessments and represent the company in communication with the State Environmental Service. If it is not clear which step to start with, an environmental consultation is usually the quickest way to find out.