Open-loop heat pump systems: permits, consents and licences

You may need to get consent, a permit and a licence from the Environment Agency before you can install an open-loop ground source or surface water source heating and cooling system.

These systems pump water from beneath the ground or from nearby rivers, canals, lakes or the sea. They use the water to heat or cool buildings before reintroducing it to the ground or surface water body.

If you want to install one of these systems you’ll need:

• groundwater investigation consent (if you’re going to drill for a ground source scheme)
• an abstraction licence (unless the volume of water abstracted is less than 20 cubic metres per day)
• an environmental permit to discharge the water (or a registered exemption from this requirement if you meet the criteria for a low risk activity)
• an environmental permit for flood risk activities or ordinary watercourse consent (if you’re carrying out works near a watercourse, a flood defence or a sea defence)

A closed-loop heat exchanger does not need groundwater investigation consent, an abstraction licence, or an environmental permit or exemption for the discharge.

There’s separate guidance for deep geothermal systems.

If you want to build a larger system (for example, for a group of homes) you may need an environmental permit or need to consider permit requirements in your design. Contact the Environment Agency if you need advice.

Have a pre-application discussion

If you plan to install an open-loop heat pump system and want advice or help with your application, you should have a pre-application discussion with the Environment Agency.

Find out about pre-application advice for water abstraction licences.

Find out about pre-application advice for environmental permits.

Get groundwater investigation consent

You need to apply to the Environment Agency for consent to investigate a groundwater source before you drill or test pump any abstraction boreholes. This consent allows you to find out what water is available and whether it’s suitable for your needs.

You will need this consent before you can apply for an abstraction licence or environmental permit for a ground source scheme. It usually takes several months from starting the consent process to getting approval for an abstraction licence, but it may take up to a year.

To apply for groundwater investigation consent you need:

• your or your company’s details
• the grid reference or a location map showing where you want to drill
• the proposed volume, rate and when you plan to use the water (for example summer only, winter only or all year round)
• details of the borehole, well or excavation you want to create
• a planning application number (if appropriate)

You must make sure boreholes, wells and excavations are designed, constructed and decommissioned in such a way that prevents groundwater pollution.

If the system you want to install allows for the reversal of flow (so that the discharge point becomes a point of abstraction) you’ll need groundwater investigation consent for all boreholes.

Contact the Environment Agency to apply for groundwater investigation consent.

You also need to inform the British Geological Survey before you drill any new boreholes.

Apply for an abstraction licence

You need an abstraction licence if you abstract (remove) more than 20 cubic metres per day from either surface water or groundwater.

If your system also requires an environmental permit for the discharge you can apply for an environmental permit and an abstraction licence using form B8.

If your system does not require a discharge permit you can apply for a separate abstraction licence.

Read the form and contact the Environment Agency if you want any advice before you apply.

If the system you’re installing allows for the reversal of flow (so that the discharge point becomes a point of abstraction) the abstraction licence covers the abstraction requirements of all boreholes.

If your circumstances or need for water changes once you have your licence, you can apply to vary or revoke your abstraction licence.

Ground source open-loop heat pump systems: exemptions

You’re exempt from needing an environmental permit for the discharge, but must register your exemption, if you have a ground source heating and cooling system that’s any of the following:

• a cooled aquifer system with a volume of less than 1,500 cubic metres per day
• a balanced system with a volume of less than 430 cubic metres per day
• a heated aquifer system with a volume of less than 215 cubic metres per day

See the guidance notes for further details on these systems.

You must also be able to meet the conditions of the exemption.

Conditions of the exemption

To be eligible for the exemption the following conditions must all apply.

The system:

• will discharge water at a temperature that will not exceed 25°C and will not vary by more than 10°C compared to that in the aquifer from which it was abstracted
• is not on a known contaminated site or one where contaminating activities used to take place – contact your local council to find this out
• will abstract and discharge within the same aquifer

The water within the system:

• will not have anything added to it – for example additives used for descaling
• will not be used for any other purpose

The system will not discharge water within any of the following:

• 50 metres of a watercourse or a groundwater-fed wetland (for example site of special scientific interest) – contact the Environment Agency or your local authority to find this out
• 50 metres of any groundwater abstraction (for example borehole, well or spring) used for any purpose
• a groundwater source protection zone 1 (SPZ1) that’s used to supply water for domestic or food production purposes

You will need to check with the owners of neighbouring properties to find out if they have a private water supply or other type of abstraction.

If you cannot meet these conditions you need to apply for a bespoke permit.

This exemption is just for the environmental permit and you must still apply for an abstraction licence and groundwater investigation consent.

Register your exemption

Download and fill in the registration form and form guidance.

Email your completed form to PSC-WaterQuality@environment-agency.gov.uk.

Or you can post it to:

Surface water open-loop heat pump systems for a single domestic property

If you have a small surface water open-loop heat pump system and comply with the conditions in this guidance you do not need to apply for an environmental permit to discharge the water.

You do not currently need a discharge permit under these specific circumstances because the Environment Agency considers it to be low risk and has issued this regulatory position statement (RPS).

Activity and conditions you must comply with

This RPS covers the discharge from a small surface water open-loop heat pump system provided:

• the system is used to heat or cool a single domestic property
• the water is abstracted from, and discharged to, the same surface water body, for example a river or stream, and not a lake or pond
• cleaning chemicals are not discharged to the surface water
• the property is not used for commercial purposes

You still need an abstraction licence if your system uses more than 20 cubic metres per day.

If your surface water system does not meet these criteria, check if you can apply for a standard rules permit. If you cannot then you must apply for a bespoke permit.

Comply with this RPS

This RPS means that the Environment Agency will not normally take enforcement action against you if you have not applied for a permit, provided:

• your activity meets the description set out in this RPS
• you comply with the conditions set out in this RPS
• your activity does not (and is not likely to) cause environmental pollution or harm human health

When to check back

This RPS will be reviewed in February 2024.

You’ll need to check back then to see whether the statement still applies or if you need to apply for a permit.

Standard rules water discharge permits for surface water systems

You may be able to apply for a standard rules permit if you discharge up to 1000 cubic metres of water a day from your heat pump system to surface water.

Applying for a standard rules water discharge permit is usually quicker and may cost less than a bespoke permit.

You must be able to comply with all the conditions of the permit.

If you do not meet the conditions for the standard rules permit you must apply for a bespoke permit.

Before you apply for a standard rules water discharge permit

Before you apply for a standard rules permit you need to:

• read the permit conditions to make sure you can comply with them
• check if you need a conservation risk assessment before you submit your permit application
• read the generic risk assessment so you can understand the potential risks and make sure you manage them effectively
• read the instructions in the application form and form guidance below
• check you meet the legal operator requirements
• check how to control and monitor your emissions - but you do not need to submit any emissions information as part of a standard rules permit application
• develop a management system (a written set of procedures that identifies and minimises the risks of pollution)

Contact the Environment Agency if you want advice or help with your application.

Apply for a standard rules water discharge permit

Download and fill in forms:

• part A: about you
• part B1: standard facilities permit
• part F1: charges and declarations

Email your completed forms to PSC-WaterQuality@environment-agency.gov.uk.

Or you can post them to

Find out about keeping sensitive information in your application confidential and what happens after you apply.

Fees and charges for a standard rules water discharge permit

You must pay an application fee of £813.

You must send payment with your application.

If your application is successful, you must also pay a yearly charge (known as the ‘subsistence’ fee) while you have a permit. The subsistence fee is £726.

If you have a thermal heat exchanger you may qualify for a lower subsistence fee of £129. Contact the Environment Agency to find out if your discharge meets the conditions.

Find out more about fees and charges. You can contact the Environment Agency for help to work out your fee.

When to apply for a bespoke discharge permit

You must apply for a bespoke permit for the discharge if you have an open-loop:

• ground source system that is not exempt
• surface water system that does not meet the conditions of the regulatory position statement or the standard rules permit

When to apply for an environmental permit for a flood risk activity

You must apply for an environmental permit for a flood risk activity if any part of your planned scheme involves construction:

• in, under, over or near a main river (including where the river is in a culvert)
• on or near a flood defence on a main river or set back remotely from it
• in the flood plain of a main river
• on or near a sea defence

You need a permit for both permanent and temporary work. There is a fee for an application.

Use the flood map for planning to check if your activity is on or near a main river or an ordinary watercourse.

If you’re carrying out work to an ordinary watercourse rather than a main river, you do not need an environmental permit for flood risk activities. You may need to apply for a land drainage consent from either your:

• local council (unitary or county council where they act as a lead local flood authority)
• internal drainage board (if you have one)

Comply with your permit

After you’ve been granted your permit you’ll need to comply with its conditions.

Find out how to comply with your permit.

Change, transfer or cancel your permit

After you have your permit, you can:

• change (vary) the details on it
• transfer it to someone else
• cancel (surrender) it

Find out how to change, transfer or cancel your permit.

Contact

Contact the Environment Agency if:

• you need help with your application
• you’re not sure if you need a permit