Following the UK Government’s plan to reach net zero emissions by 2050, the Environment Agency (EA) has begun implementing its adaption plan to combat the impacts of climate change. As part of its adaption plan the new process requires you to complete a climate change risk assessment for the application of any new bespoke waste and installation environmental permit (and part B3.5 new bespoke intensive farming installation permits).

Previously, any applicant of these permits must complete a permit application as part of the Environmental Permitting Regulations (EPR). Now, to begin, any application expected to operate for more than 5 years must also calculate your climate change risk screening score.

This score is calculated using a risk screening table that assesses:
• The length of time the permit will be required for
• The level of river and coastal flood risk at the site (low, medium or high)
• The source of water used for site operations for fire prevention (mains, surface or groundwater abstractions).

If a score of higher than five is achieved as part of this screening, you will then have to complete and submit a climate risk assessment tailored to the river basin district that the site is located within. If you have scored five or lower, as part of your permit a risk assessment must also be completed and kept as part of your environmental management system.

The climate change risk assessment is made up of a worksheet based on the data from the UK climate projections 2009 (UKCP09) that helps you qualitatively assess the impact, likelihood and severity of potential variables in climate and weather between now and 2050 that may impact operations at the site.

These variables include:
• Summer maximum daily temperature increasing by 7°C
• Winter maximum daily temperature increasing by 4°C
• The intensity of extreme rainfall events increasing by 20%
• The average daily winter rainfall increasing by 41%
• Sea level increasing by 0.6m
• 45% less rain the summer
• Variations in watercourse flow, leading to increased stress on rivers.

An example of how these variables may impact operations include how increased rainfall may affect the capacity and management plan of an effluent treatment plant, or how it could lead to the bund of a fuel tank being overtopped.
If the risk (likelihood x severity) of these variables is higher than five, than the form must include the mitigation measures of how these risks will be managed and avoided, such as increasing leachate storage capacity. The subsequent residual risk of these variables must also be calculated.

If your site has been recently redeveloped, a flood risk assessment may have been completed as part of the planning process. Evidence from this assessment including mitigation measures to address flood risk at the site can be used as part of this climate change assessment from variables such as increased rainfall events and variations in river flow. Once this information has been submitted, the Environment Agency may apply conditions to permits in order to manage climate risks. If the impacts are considered to be at an unmanageable level, then your permit may be refused. 

The EA has stated that this assessment should be considered as an extension of your current accident management plan where risks are already examined. They also stress that you should consider where climate risk hazards may combine to cause more impacts, or how climate variables may lead to more than one operational impact.
This method is part of an emerging new process for initial technical assessment as part of the duly making checks of applications and ensures that operators take responsibility for their potential contribution to climate change. Despite this only being introduced to a small number of permits, we anticipate that this assessment may be introduced as part of further compliance requirements. 

Compliance issues arising from environmental permits can give rise to significant costs, enforcements and fines, and ultimately impact the value or productivity of a business. Our environmental auditing services report on any compliance and pollution risks of operational processes, including storage, handling and processing, and where necessary suggest minor improvements which could be made to ensure your facility is following best-practice wherever possible. We can also offer assistance on how to calculate your climate risk screening score or complete your assessment.

If you would like any support on this assessment, or if you have an operational site that you would like advice on, please contact us or view our product cards for more information.
https://www.argyllenvironmental.co.uk/reports/site-inspection

Reference
https://www.gov.uk/guidance/adapting-to-climate-change-risk-assessment-for-your-environmental-permit#matrix

Lizzie Murray-Clark BSc (Hons) MSc
Environmental Consultant

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