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New climate change risk assessment for EA bespoke permits

In October 2019, the Environment Agency (EA) introduced an ‘adapting to climate change risk assessment’ for new bespoke waste installation permits and intensive farming installation applications (where the operator expects to operate for more than five years and even if you do not expect the site operations to extend beyond 2050).

Screening for a climate change risk assessment

affects of climate change include increased flood riskWhen completing the relevant environmental permit application form (Part B2 – New Bespoke and Part B35 – Farming Installations), operators are required to calculate their climate change risk screening score. The screening tool compiles three questions of which there are different answers provided with various weightings. A combined score of five or more requires the operator to complete and submit a climate change risk assessment as part of the application form. Information required to complete the screening tool includes timescales, risk of flooding and water use on site.

Completing the climate change risk assessment

Where operators score less than five, they do not need to submit the climate change risk assessment but are still required to complete one and retain it as part of the environmental management system.

A completed climate change risk assessment will consider:

  • Future summer and winter daily temperature maximums
  • Up to a 20% increase in intensity of rainfall events
  • Increase in winter rainfall
  • Sea level rise
  • Drier summers
  • Fluctuations in the flow of water course 40% more at its highest and up to 80% less than now

Note that if the operation lasts less than five years then you do not need to carry out a climate change risk assessment.

Emerging new EA process

The climate change assessment is part of an emerging new EA process for initial technical assessment as part of the duly making checks of applications. This process is becoming more complicated and arguably less transparent, making it much harder for operators to get EA permit applications duly made on the first attempt. The wider implications of this are felt through additional EA charges and significant time delays.

Charles Thomas, Consultancy Director, Wiser Environment says: “We welcome the EA changes to ensure that waste operators take responsibility for their impact on climate change. At the same time, we have concern about the increasing barriers for small businesses to enter the waste industry. We don’t want to see these operators driven out of business or underground. With extensive experience in completing bespoke permit applications, we have fed back our concerns about ensuring the climate change risk assessment is commensurate with the type and scale of activity being carried out. We are working with the Environment Agency to ensure that the process doesn’t outweigh the purpose and that potentially adverse effects on small business are minimised without compromising on the EA’s commendable effects to tackle the climate emergency.”

Net zero emissions

The introduction of the risk assessment follows Government legislating this summer for net zero emissions by 2050.

Last month, the Environment Agency announced that it planned to lead by example in the efforts to tackle the climate emergency by setting itself the aim of net zero emissions by 2030. It plans to do this through a combination of reducing emissions from its own activities and its supply chain as well as tree planting and other carbon offsetting measures.

Find out more about the EA climate change risk assessment

Wiser Environment has already completed a number of climate change risk assessments for clients submitting bespoke environmental permits to the EA. If you would like any further information or assistance on how to calculate your screening score or complete your assessment, please contact us on 01480 462 232. Find out more about our environmental permit application services.

Find out more about the EA climate change risk assessment in their adapting to climate change risk assessment guidance.