EA letter to regulatory stakeholders

Providing an update on the COVID-19 Regulatory Position Statements, the EA sent a letter to regulatory stakeholders. The letter reaffirms that the EA has provided the National Permitting Service with more resources to deal with the application backlog, extended the Continuing Competence deadline until 2021 and conducted a review of the COVID-19 Regulatory Position Statements.


EA Letter to Regulatory Stakeholders

Operators can find a copy of the EA letter to regulatory stakeholders here.

In a letter jointly signed by the Environment Agency’s (EA) Director of Regulated Industry and Director of Water, Land and Biodiversity, the EA outlines its intention to keep regulatory stakeholders up-to-date with the changes in response to the COVID-19 outbreak; recognising the difficulties some operators face in maintaining compliance during the ongoing pandemic.

National Permitting Service backlog

The EA emphasised that its teams are now fully operational and many of its offices are back open. Despite challenging conditions, the EA has incorporated digital technologies to ensure that near-normal compliance and enforcement work can continue.

However, the EA has admitted that the outbreak has negatively impacted the National Permitting Service (NPS) and its ability to process permit applications. The regulator has calculated that it is currently overwhelmed and receives over 1,000 applications a month. In response, the EA has reallocated Area Teams to support NPS directly.

According to Wiser Environment’s sources, the NPS currently has an allocation stage queue of up to 23 weeks. Notably, the average timescale for a bespoke permit to start the “duly making” process is now 18-20 weeks.

Application TypeCurrent Average Time to Initial Allocation
New Standard Rules8-10 Weeks
New Bespoke18-20 Weeks
Admin Variation6-8 Weeks
Minor Variation19-21 Weeks
Normal Variation21-23 Weeks
Substantial Variation21-23 Weeks
Transfer13-15 Weeks
Surrender15-17 Weeks
Medium Combustion Plant19-21 Weeks
Technical competence

At the start of the lockdown in March, Continuing Competence test centres closed and in June a small number of these test centres reopened with capacity restrictions. As a consequence, the EA has now agreed to extend the deadline for Continuing Competence compliance until the 1st of January 2021,

Waste industry managers whose Continuing Competence is due, have until the end of the year to take and pass the Continuing Competence Test. Wiser Environment recommends that operators book their test as soon as possible and to keep their local regulatory officer updated.

COVID-19 Regulatory Position Statements

Additionally, the EA published time-limited COVID-19 Regulatory Position Statements (RPS) to support the industry; providing operators with some compliance wiggle room. The EA outlines that the COVID-19 RPSs help operators to “minimise risks to the environment and human health where compliance with certain regulatory requirements may not be possible”. Moving forward, the EA intends to continually review each RPS; reinstating or extending particular COVID-19 RPSs should the need arise.

Expiry dates for COVID-19 RPSs
RPS NumberDescriptionExpiry Date
RPS C1Cleansing and PPE waste at a healthcare waste management facility31/03/2021
RPS C2Exceeding waste storage limits at permitted sites because of COVID-1930/09/2020
RPS C3Water and Sewerage Company OSM and UWWTR sampling affected by COVID-1930/09/2020
RPS C4Incinerating specified healthcare wastes at a municipal waste incinerator30/06/2020
RPS C5PPE waste from home healthcare workers treating patients with COVID-1931/03/2021
RPS C6Storing treated sewage sludge you cannot move because of COVID-19 restrictions30/09/2020
RPS C7Monitoring emissions from some environmental permitting activities30/09/2020
RPS C8Social distancing when signing and handing over waste transfer and consignment notes in person31/03/2021
RPS C9COVID-19 and packaging waste: registering as a packaging producer08/07/2020
RPS C10Reporting for installations, radioactive substances and waste permits30/09/2020
RPS C11Emissions to air from large combustion plant during black start events31/07/2020
RPS C12COVID-19 and spreading slurry or milk on land, or storing slurry30/09/2020
RPS C13Accumulating radioactive waste that you cannot transfer because of COVID-1931/03/2021
RPS C14COVID-19 and delaying hazardous waste consignee returns31/07/2020
RPS C15COVID-19 and exceeding permit limits for medical use of radioactive substances31/03/2021
RPS C17COVID-19 and storing waste at unpermitted sites due to exceeding your storage limits30/09/2020
RPS C18Emissions to air from Large Combustion Plant in the Transitional National Plan30/11/2020
RPS C20Monitoring emissions from some environmental permitting activities31/01/2021

EA letter to regulatory stakeholders – Additional support available at Wiser

To support the industry’s recovery from the COVID-19 setback, Wiser Environment is ready and available to help. In cooperation with clients, Wiser’s experienced team can represent waste businesses and ensure they receive the regulation they need. For more information contact Wiser Environment or call on 01480 462232.

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We offer a complete collection and recycling service – so, get in touch if you have any unwanted lights, light fittings or bulbs.

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Also, Materials recycling and handle odorous inputs or reject streams and Intensive Farming have been added to the list of Activities that require an odour management plan.