Consultation on modernising environmental permitting for industry
R&D and testing exemption for generators
At present, the EPRs exemption for R&D and testing activity applies to installations, medium combustion plant and solvent emission activities, but not to ‘specified generators’, although the EA has issued a Regulatory Position Statement (RPS) that it will not generally enforce permitting requirements on R&D testing for specified generators assuming certain conditions are met.
The lack of an exemption risks placing a disproportionate regulatory burden on small sources of emissions, and there is not a clear reason to treat generators differently from other types of industrial facilities under the EPRs. The current approach of using an RPS reduces certainty for operators, as it is not a permanent feature of the regulatory framework.
We are therefore minded to consult on the option of exempting specified generators which are used for research, development or testing, and would appreciate feedback on this option.