After the Act on the Integrated Management of Environmental Pollution Facilities (the “Integrated Management Act”) entered into force on January 1, 2017, ten environmental permits relating to air, water quality and waste under seven statutes have been combined into an integrated environmental permit system (the “integrated system”).1
Having started with electricity generation, steam, and waste treatment industries in 2017, the integrated system will apply to a total of 19 industries (1,411 worksites) by 2021. Any permits filed after the enforcement of the Integrated Management Act are subject to the integrated system, while worksites existing prior to the enforcement are required to obtain an integrated permit within four years from the time when the relevant industry becomes subject to the system. Accordingly, existing worksites in the industries subject to the first application (2017) of the integrated regime must obtain an integrated permit within the grace period that ends on December 31, 2020. Thus, it is recommended that concerned worksites examine their preparation status to ensure that they can obtain an integrated permit within the grace period.
Industries Subject to the Integrated Environmental Permit
| Year | 2017 | 2018 | 2019 | 2020 | 2021 |
| Worksites (1,411) |
320 | 315 | 165 | 134 | 477 |
| Industries (19) |
Electricity generation, steam, waste treatment | Non-ferrous materials, steel, organic chemistry | Petroleum refinement, fertilizer, inorganic chemistry | Pulp/paper, electronic parts | Semiconductor, auto parts, alcohol |
Under the integrated system, the Minister of Environment itself will grant integrated permits instead of regional environmental offices, cities and provinces. As applications for integrated permits are expected to be concentrated in 2019 and 2020, the Ministry of Environment is currently preparing to expand its organization by improving the “environmental review board” (recently relocated to Sejong City) that will undertake technical reviews of integrated environmental management plans and post-management of worksites.
Once enforced, the integrated system will require (i) the application of the Best Available Techniques (BAT); (ii) the submission of integrated environmental management plans; and (iii) post-management reviews (e.g., regular reviews of permit conditions and permitted emission/discharge standards in a five-year interval).
In light of the foregoing, worksites should prepare in advance of becoming subject to the integrated system or being required to file a permit. In addition, it is also advised for entities that are intending to improve and establish or expand worksites to consider general matters that are relevant to the integrated system.
