Dr Tom Stafford is an expert in environmental policy and regulation with over three decades of experience in environmental protection, sustainability, and industrial permitting. He has been involved in the IED Serbia project since its first phase as an international technical expert.
Dr Stafford spent nearly 19 years at the Environmental Protection Agency (EPA) Ireland, holding senior manager positions responsible for national environmental reporting, data management, and IED permit enforcement. At the EPA, he also managed the environmental auditing function and implemented ISO 9000 quality management systems across permitting and enforcement functions. He served several years as an Inspector and permit writer for industrial (IPPC) Permits.
In 2014, he moved to Irish Water to become Environmental Regulation Manager, overseeing compliance for Irish Water’s approximately 1000 wastewater treatment plants and 900 drinking water treatment plants. More recently, he has managed Irish Water’s Sustainability function, overseeing strategies for carbon reduction, energy efficiency, and the circular economy.
His international experience began in 1996 on a twinning project establishing an EPA in Latvia. Since then, he has participated in projects in Bulgaria, North Macedonia, Georgia, Azerbaijan, Ethiopia, and, of course, Serbia. His work in Serbia started in 2009 on a UNDP project with the Ministry on IPPC permitting. He later participated in a Twinning Project with the Austrian EPA (UBA) assisting the Sector for Control and Surveillance, and then joined the IED Serbia project in 2015. In these projects, he has focused on developing environmental policy, regulation, permitting processes, and institutional capacity building, applying his experience and learnings from his career in Ireland.
IED Serbia: Tom, can you introduce yourself and share insights from your extensive experience as an Environmental Regulation Manager with the Irish EPA? What key lessons and expertise do you bring to your current role in Serbia, working with industry, local experts, and competent authorities on environmental protection?
Dr Tom Stafford: I have been in the field of environmental regulation since starting my working career. My first job, as part of university work experience, involved an effluent survey at a brewery to identify key sources of high BOD waste streams.
After finishing my degree, I completed a PhD focused on land contamination by chlorinated solvents and their degradation by bacteria.
Following my PhD, I joined a company involved in the then very new area of implementing environmental management systems. This was before ISO 14000 existed, when British Standard 7750 was the focus. This experience influenced my view on environmental management and adopting a systematic approach to improvements.
I moved from consultancy to join the EPA shortly after its establishment in 1994, joining the permitting team. At that time in Ireland, we were setting up the system for issuing integrated pollution control licences, a new type of licence that predated the IPPC directive of 1996. It was an exciting period as we figured out the best approach – what was reasonable and what would or wouldn’t work. I learned a huge amount from that process, lessons which have remained with me. A unique approach at the EPA then was combining roles: having written a permit, you were also responsible for its enforcement. This provided significant insight into how well written permits worked in practice.
I then established the environmental auditing team to undertake more detailed enforcement visits to IPPC permitted facilities. As we issued more IPPC licences, we began to specialise in enforcement. As part of this work, I implemented quality management systems across permitting and enforcement to improve consistency and rigour. We later made the decision to completely split the permit writer and inspector roles and set up a new department for enforcing IPPC permits, which I managed for several years. This provided extensive direct experience in dealing with issues at IPPC facilities and determining the best ways to achieve environmental improvements, sometimes requiring enforcement actions, including criminal prosecutions. This experience was invaluable for managing and enforcing compliance at IPPC facilities.
I then moved to a new section responsible for much of Ireland’s environmental reporting to the European Commission and European Environment Agency. Here, I set up data management systems to collect, analyse, and report data on a wide range of environmental issues. Around 2000, the Water Framework Directive came into being, and I was heavily involved in establishing Ireland’s systems for managing WFD data, including characterisation and pressure mapping of water bodies. I also participated in the European Commission’s drafting group for WFD reporting requirements. My involvement in reporting under the Bathing Water, Urban Wastewater, and Drinking Water directives at that time gave me a deep understanding of water-related issues.
In 2014, the government decided to establish a new national water utility, Irish Water, taking over responsibility from municipalities for providing drinking water and wastewater services. I was involved in some of Irish Water’s setup work, particularly data management, as the EPA was arguably the best equipped organisation in Ireland for water data management at that time. I decided to move to Irish Water, taking up the post of Environmental Regulation Manager to establish the necessary systems and controls for assessing and managing compliance of our wastewater and drinking water treatment plants and the drinking water supplied to the public. This gave me a new perspective on regulating enterprises – being regulated rather than the regulator. I also gained a deep understanding of asset management and what infrastructure projects require to update and improve water and wastewater assets.
I then made a sideways move within Irish Water to lead a new area in sustainability, which was becoming more central to the organisation. I was responsible for developing the organisation’s policy, goals, and frameworks for sustainability targets, including carbon reduction and energy efficiency targets. More recently, the focus has been on developing systems and generating information to meet the requirements of the Corporate Sustainability Reporting Directive and EU Taxonomy regulations.
IED Serbia: You are engaged as an expert in the “Green Transition – Implementing Industrial Emissions Directive in Serbia 2021-2027” project, focusing on drafting integrated permits for selected industrial operators and transferring knowledge to Serbian inspectors through theoretical and practical training. Can you tell us more about your role and the impact of these activities?
Dr Tom Stafford: I primarily view my role as sharing experiences and lessons learned from my career to advise people on what works and what we have found doesn’t work, essentially benefiting from our past challenges. The focus is primarily on knowledge transfer.
I have spent many years in Serbia working with dedicated people across various organisations, including the Ministry, the Sector for Control and Surveillance, the Provincial Secretariat, Municipalities, and the Serbian EPA. I find them all to be experts in their fields with deep knowledge and passion for their work. So, our role is less about dictating methods and more about offering guidance and assistance.
Specific project tasks over the years have included developing rulebooks for intensive agriculture, creating guidance documents, and providing training to permit writers and inspectors.
Currently, we are focusing on training permit writers, especially in the context of the new environmental law transitioning from IPPC to IED permitting. We are covering the full scope of activities a permit writer needs to be aware of. We are in the middle of a training programme consisting of three two-day workshops designed to establish a solid basis in IED permitting.
We also conduct training inspections with inspectors. We visit an IED facility, examine particular aspects of a permit, and discuss approaches to these issues with the inspectors. We also engage with the operators for useful and constructive discussions on moving forward with identified issues. This provides inspectors with practical insight into inspection approaches and an opportunity to ask questions and share experiences.
IED Serbia: One key project activity is supporting the Ministry of Environmental Protection in preparing a revised draft of the Directive Specific Implementation Plan (DSIP) for the Industrial Emissions Directive (IED). You recently visited several industrial operators across Serbia – can you share your insights and key observations from these visits and the overall process?
Dr Tom Stafford: By and large, we have been very impressed with the facilities visited in Serbia. Most are of a comparable standard to their counterparts in Europe, and some rank among the best. Many installations face the same challenges as European facilities in complying with very stringent BAT requirements, which demand significant investment.
Compliance with the IED requires substantial investment. Capital investment plans take a long time to plan and implement, so making installations aware of the requirements as early as possible benefits everyone.
During a visit to an industrial facility in Belgrade, we observed that significant investment would be needed, particularly for large combustion plants, to meet IED requirements. However, we were encouraged to see the installation was highly focused on reducing energy consumption and carbon generated per tonne of product. This focus is a precursor to investments in energy generation and emission abatement technologies. This sustainable approach aligns well with the principles of the new IED, which envisages companies undertaking deep transformations. The ultimate objective is to produce products with very low or zero carbon emissions – a challenge industry will face in the future.
The message is that while significant investment is needed for BAT compliance, the key is investing wisely in lower emission processes rather than solely relying on expensive abatement solutions.