Does anyone here have experience of applying for an Environment Agency permit?

[Drellingore]

Does anyone on BuildHub have personal experience of applying for an EA permit to discharge domestic effluent, either to ground or to surface water? 

 

I'm wondering what their attitude is to making multiple applications simultaneously. We've got four broad approaches we might be able to take, pending approval/further information:

 

1. Use a cesspool (ie no permit required, but it's environmentally and financially unsustainable)
2. Discharge to a ditch/gulley (ie surface water discharge) on the other side of a public road, via a land drain that we think leads there
3. Discharge to a drainage field, which is a bit too large to easily accommodate
4. Discharge to infiltration tunnels, which are much smaller and can be driven over (which means we can make better use of the space, especially as there's a bit of 'dead land' that a neighbouring farmer has a right-of-access over)

 

Pre-application advice hasn't yielded great results so far, I've just had automated responses. I'm tempted to pay for enhanced pre-application advice at £100/hour, in the hope that I get to speak to a human. Failing that, it'll be a matter of making applications and seeing if any get accepted.

 

My questions to anyone with experience are:

 

• Is enhanced pre-application advice actually useful?
• Did the EA open a dialogue as part of an application, or was it three months of waiting in silence for a binary yes/no?
• Is there any evidence that making three different applications for the same site will prejudice our chances?

 

Notes for people kind enough to consider replying:

• Yes, I probably do need a permit owing to being in groundwater source protection zone 1. If we can discharge to the ditch/gulley and make the case that it doesn't dry up, we might be covered under GBR, but I'm still in the process of exploring that option.
• No, I'm probably not doing this in the wrong order - planning was granted with subsequent approval of a drainage strategy as a planning condition.
• No, I'm not willing to just do whatever and hope no-one notices, as we're close to a water extraction point and there is anecdotal evidence of the water company being extremely sensitive as to what shows up in the supply.
• No, I really don't want a cesspool. It's 12PE, 80m3, and about £25k plus perhaps up to £4k/year in emptying fees.

 

Ta in advance

[ToughButterCup]

I think you need proper, qualified, intelligent and intelligible advice.

PM for a phone number. His name is Paul Usher: here's his bio . He works for one company, but - to me anyway - gave unbiased, independant  and extremely valuable advice

[Drellingore]

7 minutes ago, ToughButterCup said:

I think you need proper, qualified, intelligent and intelligible advice.

 

Thanks, I think you're right. PM sent.

 

We paid one company to do a drainage strategy when we were even less informed than we are now, and it was cack - unimaginative, and they even used out-of-date drawings, leading to a payment dispute! I called around a few drainage consultants, and got lots of teeth-sucking followed by "no chance, mate". I got on to the EA after that, and it was they who first suggested that it might be possible to do something other than a cesspool, and that's what the permit application process is there for.

 

I think I then gave up on paid advice on the grounds that the EA were saying there was some chance, and consultants were telling me there was no chance. So maybe it's time I spoke to a good one

[Russell griffiths]

I’m not understanding your problem, you have posted multiple times regarding this. 

 

my own experience. 

Our site is a SSSI under the supposed control of Natural England, we have a large lake on site of 7 acres and another of an acre. 

We employed a hydrologist to provide calculations for rainwater discharge and what to do about the treatment plant. 

He came back saying that all discharge from the treatment plant can go straight to the lake !!!!!

i was never happy with that idea and did something slightly different with a catchment pond before the lake. 

 

We sent it all in with building regs and it just got got ticked off. 

 

Im sure building control are just interested in you supplying them with a method, they don’t really care too much about the method they just want to tick that box and go for lunch. 

 

Not understanding why your discharge doesnt doesn’t go straight to a filter-bed soakaway. 

 

What im getting at is that for an ecologically sensitive site mines probably 100 times more protected than yours, and I have 3 tanks on site and two of them discharge to soakaway and the new one straight to a pond. 

 

Edited February 28, 2023 by Russell griffiths

[Drellingore]

13 minutes ago, Russell griffiths said:

I’m not understanding your problem, you have posted multiple times regarding this. 

Yeah, I seem to not be making things clear!

 

13 minutes ago, Russell griffiths said:

Not understanding why your discharge doesnt doesn’t go straight to a filterbed/ soakaway. 

 

It's in groundwater source protection zone 1 which means that, as established in one of those other threads, I cannot meet the general binding rules for a discharge to ground as you suggest. If I cannot meet the general binding rules, then without a permit from the Environment Agency it would be an unauthorised discharge which a UK government website informs me is a breach of criminal law:

 

 

Building control cannot give me a permit. Only the Environment Agency can. I'd generally, as a rule of thumb, prefer to avoid breaking the law. I find it leads to a simpler life!

 

Please let me know if that doesn't clarify things.

Edited February 28, 2023 by Drellingore

[saveasteading]

The priority should be to prevent pollution especially of the aquifer. If you design for that you will get permission.

Secondly actually do it right and you won't kill people or get fined.

 

Finding a stream would have been a bonus, but it looks like you need this designed appropriately with a professional document to prove it.

[dpmiller]

Certainly with NIEA, the process is simple and we had no difficulty discharging into an open field drain which leads directly to a RAMSAR/ ASSI/ AONB zone and the site itself is within the AONB

[Drellingore]

15 minutes ago, dpmiller said:

Certainly with NIEA

 

I get the general impression from reading BuildHub that self-building is a much more enjoyable affair in the other parts of the UK  I'll console myself by convincing myself that at least we have less rainy weather where I am!

[joe90]

I found the EA very helpful when applying fir my discharge from our STP.

[saveasteading]

2 minutes ago, Drellingore said:

self-building is a much more enjoyable affair in the other parts of the UK

No. The hurdles are much the same and for the same reasons.

Don't worry, you will get there, and the multiple options gradually converge to a solution.

Nobody is out to catch you out but, at some stage, you stop studying the options and choose a way ahead that the authorities will be happy to agree to.

 

I have had the 'pleasure' of training the family in construction as they are on site and I am far away. Their main worries have been that there are so many things to consider technically, financially and aesthetically, all at once.

But, but but...and then it gets complicated by some experts and many non experts with differing ideas and knowledge.

[saveasteading]

2 minutes ago, joe90 said:

I found the EA very helpful

ditto. They are under-resourced and overworked and much blamed, but real people trying to help. The ones that deal with drainage are not tree huggers but qualified and sensible.....that I have encountered anyway.

I like that they always accept my proposals (not always the obvious) , so they are by definition very astute and sensible.

[crooksey]

Just to add, you can pay private building controllers for a "plan check service". The route you could go down is:

 

1) Get proper system design done (after percolation testing)

2) Submit the design for a plan check to building control/approved inspector, I imagine this would cost in the region of £1000

3) If building control pass the plan check, they can also then submit the design to the local water authority for comment (this is what's done in a normal building regs application pre commencement for a new STP).

4) If all of the above come back good, submit it all to a bundle to the EA, then they will have everything they need to make a decision.

 

 

 

 

[Drellingore]

For anyone discovering this thread in a historic search: we got a phone call to tell us that a case officer was assigned on Thursday last week (6th July). The application was made on 28th April, so almost exactly ten weeks. Again, the EA person I spoke to was very helpful.

[Dave Jones]

ring them up and say you can see turds in the ditch. you will have a free onsite visit in under half an hour. Then you can pick their brains....

[Drellingore]

Following up to let any future forum-searchers know that the assigned officer at the Environment Agency was incredibly helpful. She spoke to me on the phone, queried anything that needed to clarification (I'd made a couple of mistakes that she'd corrected for me and wanted me to confirm), and made herself available to contact on the phone.

 

I was worried that the whole thing would be geared up to be a bureaucratic assault course, looking for any excuse to reject your application so that they wouldn't have to deal with it. Turns out to be the exact opposite, once you get through to speaking to assigned officers.

 

Whole thing has been 14 weeks and 4 days since initial application to get a final permit, and this included a week or two of revisions owing to errors on my part.

 

5*, A+++, would apply for a permit again, etcetera

[saveasteading]

Good to hear. 

I've always found EA officers to be fair, and genuinely interested in their work.

 

They spend a lot of their time dealing with problems and polluters, so a person trying to do things properly will be welcome.

 

Unfortunately  their numbers have been halved, and they aren't allowed to speak out against government policy on housing and water/sewage  companies.

[EViS]

On 09/08/2023 at 08:49, Drellingore said:

Following up to let any future forum-searchers know that the assigned officer at the Environment Agency was incredibly helpful. She spoke to me on the phone, queried anything that needed to clarification (I'd made a couple of mistakes that she'd corrected for me and wanted me to confirm), and made herself available to contact on the phone.

 

I was worried that the whole thing would be geared up to be a bureaucratic assault course, looking for any excuse to reject your application so that they wouldn't have to deal with it. Turns out to be the exact opposite, once you get through to speaking to assigned officers.

 

Whole thing has been 14 weeks and 4 days since initial application to get a final permit, and this included a week or two of revisions owing to errors on my part.

 

5*, A+++, would apply for a permit again, etcetera

Thanks for sharing the updates. Could you elaborate on what your final drainage scheme design consists of and what the permit covers?

[Drellingore]

Sure. A Solido Smart 10PE (we actually need 12PE, but the standards vary between Germany and the UK, so 10 Germans emit the same amount of effluent as 12 Brits - must be all the currywurst) is all that's required for treatment in groundwater source protection zone 1. The EA encouraged (but chose not to force) us to use the tertiary system that we specified, which was 4x Tricel PuraFlo modules.

 

Our infiltration rate was 19.8vP (I did all the tests myself, so I can advise on this as well if that is of use). For a BS6297 infiltration field, that required an infiltration area of 47.52sqm, which in turn translated into a minimum total infiltration field size of 110sqm. This is because the runs of pipe need space between them, and there's an external margin required all the way around the field.

 

Graf helped us spec up an infiltration system using their tunnels that only needed to be three tunnels long, but they apply a "safety factor" of two, so they recommended six tunnels in total. We chose to arrange these in two runs, rather than one long one. The total size of the tunnel infiltration system is 14sqm, which is a huge difference.

 

The whole thing will be cheaper and more sustainable than the default in groundwater source protection zone 1, which is a cess pool. We have other challenges to overcome in getting this approved by the local planning authority, but those are particular to our circumstances and probably best left undocumented in public until we've got it sorted; I'm sure my other posts give the game away if you're really bored.

 

I hope that helps, please let me know if I can answer any other questions.

[Drellingore]

On 29/08/2023 at 17:44, EViS said:

what the permit covers

 

Oops, forgot this. It states the location, the volume of treated effluent, the amount of ammoniacal nitrogen (interestingly not any other metric), the sampling points, the infiltration mechanism and dimensions, the depth, and a few restrictions (ie no surface water run-off to go through it). There's a non-binding introductory note, a site plan, notification process in case of deviation/failure, and three pages of conditions that basically form the 'contract'.

[saveasteading]

1 hour ago, Drellingore said:

total size of the tunnel infiltration system is 14sqm, 

As opposed to 140m2. Into the same ground! Any logic you know of to justify this?

Mine, speculatively,  is that 140m2 is stupidly excessive(*), being only 20% less than for cess tank effluent but nobody has bothered to test and change it...but that Graf have made a thing and tested it.

(*) and from my enquiries is simply ignored by EA  , BCO et al, and not done.

[Jon_hfd]

On 30/08/2023 at 18:52, Drellingore said:

Sure. A Solido Smart 10PE (we actually need 12PE, but the standards vary between Germany and the UK, so 10 Germans emit the same amount of effluent as 12 Brits - must be all the currywurst) is all that's required for treatment in groundwater source protection zone 1. The EA encouraged (but chose not to force) us to use the tertiary system that we specified, which was 4x Tricel PuraFlo modules.

 

Our infiltration rate was 19.8vP (I did all the tests myself, so I can advise on this as well if that is of use). For a BS6297 infiltration field, that required an infiltration area of 47.52sqm, which in turn translated into a minimum total infiltration field size of 110sqm. This is because the runs of pipe need space between them, and there's an external margin required all the way around the field.

 

Graf helped us spec up an infiltration system using their tunnels that only needed to be three tunnels long, but they apply a "safety factor" of two, so they recommended six tunnels in total. We chose to arrange these in two runs, rather than one long one. The total size of the tunnel infiltration system is 14sqm, which is a huge difference.

 

The whole thing will be cheaper and more sustainable than the default in groundwater source protection zone 1, which is a cess pool. We have other challenges to overcome in getting this approved by the local planning authority, but those are particular to our circumstances and probably best left undocumented in public until we've got it sorted; I'm sure my other posts give the game away if you're really bored.

 

I hope that helps, please let me know if I can answer any other questions.

Hi Drellingore

This thread has been really helpful, thanks for posting.

I've contacted Graf regarding the calculations, but heard nothing back. Would you be able to share with me what they provided?

Many thanks in advance

 

Jonathan

[Drellingore]

DM's sent!

[Jon_hfd]

On 19/01/2024 at 14:13, Drellingore said:

DM's sent!

Thanks, much appreciated.

 

One other related question does anyone have experience regarding allowable distances to property?

The rule for a soakaway is 5m, whereas the rule for a drainage field is 15m. If the EA agree to the use of a soakaway, does this still have to be 15m, or can it be 5m?

Am I right in thinking this is a BC issue, and has anyone had any luck with getting a reduced distance agreed?

 

Many thanks

 

Jonathan

[saveasteading]

1 hour ago, Jon_hfd said:

getting a reduced distance agreed

I got permission for a soakaway at 4m.

There wasn't any alternative, the original architect had messed it up, and the bco agreed it was OK in the circumstances.

There's nothing magic happens at these distances but it may depend on site circumstances.

[Alan Ambrose]

>>> so 10 Germans emit the same amount of effluent as 12 Brits - must be all the currywurs

 

I just had to explain to the other half why I was laughing so much…