Environment and sustainability
Ghana EPA permit renewal: the four things that cause delays
Permit renewal is a paperwork exercise right up until the point it is not. Four issues account for most of the delays we see.
Renewal should be routine. When it is not, it is usually for one of four reasons, and all of them are avoidable if you start early enough.
1. Monitoring gaps
The most common issue by some distance. The permit specifies monitoring parameters and frequencies. Twelve months later the record has holes in it, usually where equipment was down or a sampling round was missed during a shutdown. There is no way to retrofit a measurement that was never taken. The only remedy is an honest account of the gap and a corrected programme going forward.
2. Unclosed conditions from the previous cycle
Permit conditions frequently include commitments with deadlines. If nobody owned them, they are still open. Reviewing the previous permit conditions six months before renewal, rather than six weeks, gives you time to close them properly.
3. Changes that were never notified
Process changes, capacity increases, new storage, a new discharge point. Where these were not notified at the time, renewal is when they surface. This is a management of change failure more than an environmental one.
4. The report is late
The Annual Environmental Report takes longer to compile than most teams allow, particularly where monitoring data sits with several different people in several different formats. Start the compilation early and keep the data in one place through the year.
A practical routine
Diary the renewal eighteen months out. Review the permit conditions at twelve months. Audit the monitoring record at nine months. Begin compiling the annual report at six. None of this is difficult. It just has to be somebody actual job.