5.6 Proposed Contents of the Licence Application

The NEMC Act may only stipulate the generic contents that may be in a pollution license. The detailed contents, however, may be covered by regulations. The application should contain details of environmental profile of the applicant's facility including: the surroundings, manufacturing process, pollution prevention, mitigation measures, among other aspects. A model can be seen in the UNEP Manual on Industry and Environment (UNEP Office/UNIDO): Audit and Reduction Manual for Industrial Emissions and Wastes, (1991). The manual contains examples of how to carry out a material
balance indicating material and energy inputs and outputs in flow chart form, including emission to the environment.

It is recommended that the applicant, rather than the regulatory authority propose the compliance plan, because the applicant would known industrial processes and discharge systems better than anybody else. In addition, if the applicant certifies a certain method and schedule of compliance that it can achieve, and yet does not abide by it, then enforcement mechanism can be initiated. (ELI,1993)

Interim measures and deadlines to fulfil the compliance plan should be included in the plan and be monitored. The interim measures enable the facility to take some steps before the time allotted for compliance has expired. The application should also provide for an emergence preparedness plan and methods of dealing with anticipated emissions levels. Waste treatment and disposal methods should also be described.

Monitoring and reporting mechanisms should also be spelt out in the application, once EIA is a legal requirement, new applications for a licence will have to incorporate their EIA reports with their applications. EIA will contain mitigation measures and options to reduce possible impacts on the environment and thus, need not be duplicated in the licence application.
The license should also spell out what breach of any term or condition in it, is an offence.