Climate change adaptation plans – New requirements for existing environmental permit holders (England)

Guidance has recently been updated by the Environment Agency on how to develop a management system so that you can carry out activities under an environmental permit.

The new guidance states that if your permit was issued:

• on or after 1 April 2023, you need to integrate climate change adaptation planning into your management system
• before April 2023, whilst your management system should already consider climate impacts, you need to complete a climate change adaptation risk assessment by 1 April 2024

Planning for an increased risk of climate change impacts will help you to:

• remain in compliance with your environmental permit, other obligations and regulations
• minimise your impact on the environment during an extreme weather event and the event’s impact on your operations, either through accidental release or abnormal operation
• improve your resilience and business continuity by avoiding unplanned start-ups, shutdowns and other business interruptions

You will need to consider:

• the risks to your business from climate change
• the risks your business creates due to climate change
• how to embed controls

Outlined below are some examples of how changes in climate can impact a business.

The detail in your risk assessment and plan of action should reflect the risk that climate change creates for your operation. First, you need to consider how vulnerable your site is to current and future climates. You should assess for a 4°C rise by 2100 and plan for a 2°C rise by 2050. The potential impacts should be both site-based and sector-based, i.e. relevant to your site and business activity. You then complete a risk assessment. If your operation is at high risk, you will need to complete a more in-depth risk assessment using best available climate change information and considering the timescales of more likely impacts. You then need to find control or management measures for the significant risks, write your climate change adaptation plan in line with a suitable standard, such as ISO 14090:2019, and embed it into your management system.

The Environment Agency will inspect or audit your climate change risk assessment and adaptation plan periodically. This will be as part of wider checks on your management systems during routine compliance assessment activities.

They will plan this regulatory work based on the significance of extreme weather threats, so that it’s proportionate to:

• the hazards and risks associated with your business
• the potential for climate change to influence the risk

They will also audit your adaptation plan after any significant pollution event that they believe was related to severe weather.

SLR provides technical expertise in the following areas, should you require assistance preparing a climate change risk and adaptation plan:

• Undertaking standard and in-depth climate change risk assessments
• Development and implementation of climate adaptation plan
• Environmental management systems
• Environmental compliance auditing
• Environmental permit applications

If you would like more information on how SLR can assist, please get in touch.