If you hold an Environmental Permit issued by the Environment Agency, you need to integrate climate change adaptation planning into your management system and complete a climate change adaptation risk assessment by 1 April 2024.
Ahead of this deadline, Delta-Simons’ EHS Principal Consultant, Sam Smith outlines climate change projections, stresses the need for businesses to assess and address potential impacts on their operations and details how Delta-Simons can help you plan and prepare for a changing climate.
Preparing for Climate Change in your Management System
All sites with an Environmental Permit are required to have a written management system in place to minimise risks of pollution caused by the permitted activities. The Environment Agency provides guidance on the necessary components of these management systems and one of the newer requirements is to understand if a changing climate could affect your operations and your ongoing ability to comply with your permit.
Climate change projections suggest that we can expect Physical Climate Risks and impact to site operations e.g. through:
- Higher average temperatures – particularly in summer and winter
- Increased frequency of heat waves, hot days and wildfires.
- Rising sea levels
- Changes in rainfall patterns and intensity
- Increased frequency of extreme weather such as storms
Considering these changes, it is important to plan appropriately and implement changes, if and when required to try and reduce future impacts. Reviews and revisions should be made in response to new information and plans should include ways to test the effectiveness of the actions, policies, procedures and assessments.
What is required and when?
In April 2023, the Environment Agency updated their guidance to explain when permit holders will need to meet the requirements for climate adaptation planning.
Specifically, 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.
Further guidance explains that the process should follow the steps below:
- Prepare – Review what processes are already in place.
- Assess potential impacts – Consider how vulnerable the site is to current and future climate change.
- Complete the risk assessment – Consider the current and future activities and threats, including all known or reasonably foreseeable site-specific climate impacts.
- Find control measures – Gather information on options available to address the risks. Assess if they are reasonably practical and affordable to ensure compliance with the Environmental Permit.
- Write your climate change adaptation plan.
- Monitor, record and review your plan.
What happens if I do nothing?
It is likely that the Environment Agency will inspect your Climate Change Risk Assessment and Adaptation Plan periodically, as part of their wider checks on your management system. The Environment Agency may also audit the Adaptation Plan and Risk Assessment after any significant pollution event if it was related to severe weather.
If you do not have the required planning and adaptation built into your management system by the deadline, you may be subjected to enforcement actions depending upon the circumstances and severity.
How can Delta-Simons help?
Delta-Simons is a multi-disciplinary environmental and health and safety consultancy providing trusted advice and solutions. As part of the Lucion Group, we ‘Protect People and Planet’ through facilitating sustainable development through our holistic suite of services. As such, we can guide you through each step of your climate change risk assessment, planning and adaptation.
An important element of the process is to understand the short, medium and long-term risks posed to your site from Physical Climate Risks such as flooding. Delta-Simons’ dedicated Water Services team specialise in Flood Risk and Climate Resilience Assessments as well as the wider Physical Risk Climate Assessments.
As such Delta-Simons is perfectly placed to provide robust, data-driven support to ensure your climate change risk assessment planning and adaptation is comprehensive and appropriate to your site. Finally, our services, where appropriate, work towards Task Force on Climate-Related Financial Disclosures (TCFD) compliance and alignment with EU Taxonomy to help our Clients more effectively disclose climate-related risks and opportunities.
