Comment

Representation ID: 23176

Received: 11/10/2021

Respondent: Environment Agency

Ground Source Heat Pump (GSHP) systems can be used for heating or cooling and are, in principle, energy and CO2 efficient. However, unless they are managed carefully there is the potential that the ground and groundwater can eventually warm or cool to a point where the system cannot continue to operate efficiently, or at all. Adjacent systems may also interfere with each other. The system operator should also consider
potential for loss or damage to third parties. The following key issues should be taken into consideration:

• Risk of the pipes or borehole(s) creating undesirable connections between rock or soil layers. This may cause pollution and/or changes in groundwater flow and/or quality.
• Undesirable/unsustainable temperature changes in the aquifer or dependent surface waters.
• Pollution of water from leaks of polluting chemicals contained in closed loop systems.
• Pollution of water from heat pump discharge from an open loop system that contains additive chemicals.
• Impacts of re-injection of water from an open loop system into the same aquifer, both hydraulic and thermal, as well as any water quality changes induced.
• The potential impact of groundwater abstraction for ground source heat systems on other users of groundwater or surface water.

We expect developers to undertake appropriate prior investigations for these systems. This should include environmental risk assessment and method statements for the construction and operation of the systems. These may be provided as part of the planning process.

Any proposals for renewable and low carbon energy generation may be subject to the requirement of the Environmental Permitting Regulations and therefore require an environmental permit under the Environmental Permitting (England & Wales) Regulations 2016, from the Environment Agency, unless an exemption applies. For such proposals we recommend that the Environment Agency is contacted for further advice and to discuss the issues likely to be raised.

Surface water heat pumps may also require permits from the Environment Agency. A national code of practice has been published by the Chartered Institute of Building Services Engineers (CIBSE). The Code sets minimum requirements and recommends best practice, allowing developers to include it as part of the tendering/contract process for a project. The work has been supported by the Department for Energy and Climate Change, with the Environment Agency as an active member of the project steering group. The Code is available to purchase through CIBSE but you can read more about it in their summary leaflet here: leaflet

More information on the permits required from the Environment Agency for both ground source and surface water source systems is available here: https://www.gov.uk/guidance/open-loop-heat-pump-systems-permits-consents-and- licences

12.48 - Any proposals for coal bed methane exploration will need to be considered for a permit under the Environmental Permitting (England & Wales) Regulations 2016, from the Environment Agency, unless an exemption applies. For such proposals we recommend that the Environment Agency is contacted for further advice and to discuss the issues likely to be raised.