How the Environment Agency makes decisions on landfill engineering
Source: gov.uk (2025-05-14)

What the Environment Agency requires from you when you design and construct a landfill site.

Design and construction: landfill engineering and infrastructure

You must design and construct landfills using sound scientific techniques and detailed calculations to protect the environment from the particular risks at the proposed location. This is known as ‘landfill by design’.

The Environment Agency assesses landfill permit applications, and compliance with permit conditions, to make sure:
- operators carry out appropriate risk assessments before and during design and construction, and apply standards that are appropriate to the risks they identify
- new techniques and materials are developed and used where they are scientifically sound, particularly when they will improve environmental protection
- all landfill engineering complies with your permit conditions
- all landfill engineering and infrastructure meets the required standards and has independent third party assurance and validation – check the required standards (https://www.gov.uk/guidance/landfill-operators-environmental-permits/design-and-build-your-landfill-site#design-requirements) and what we mean by landfill engineering and infrastructure (https://www.gov.uk/guidance/landfill-operators-environmental-permits/construction-quality-assurance-cqa)
Landfill design principles

Your landfill design must follow the design and build your landfill guidance (https://www.gov.uk/guidance/landfill-operators-environmental-permits/design-and-build-your-landfill-site) and landfills for inert waste guidance (https://www.gov.uk/guidance/landfill-operators-environmental-permits/landfills-for-inert-waste). The design must be based on risk assessments and take account of sustainability.

You must:
- consider the environmental performance of the various design options available
- adopt a precautionary approach when selecting options
- incorporate appropriate factors of safety into the design that are proportionate to the consequences of failures
Planning permission and environmental permits

Planning permission

The location of your landfill must be approved by your local waste planning authority.

The design and operation of your site must be approved by the Environment Agency.

You can submit your applications for planning approval and an environmental permit at the same time.

The Environment Agency will object to a planning application where the proposal does not meet the groundwater protection position statements: chapter E landfill (https://www.gov.uk/government/publications/groundwater-protection-position-statements), when they are consulted by the planning authority. If you get planning permission contrary to this policy, the Environment Agency is likely to refuse your permit application.

How the Environment Agency assesses your permit application

The Environment Agency must be satisfied that your permit application complies with the relevant legislation and is appropriate to protect the environment. If it is not, you will be asked for more information during the permit application process.

You must provide an ‘in principle’ engineering design with your application. You must base this on your risk assessments.

The Environment Agency will make a decision on your permit application after it has:
- consulted with statutory consultees – as set out in its public participation statement (https://www.gov.uk/government/publications/environmental-permits-when-and-how-we-consult)
- carried out a technical assessment of your application
The Environment Agency cannot approve your application if the information you provide is not adequate.

Get approval for landfill engineering

When the Environment Agency has granted your permit, you must not deposit any waste at your site until you have submitted:
- your construction proposals and construction quality assurance (CQA) plan to the Environment Agency and it has approved them
- a CQA validation report for the construction work and the Environment Agency has confirmed it’s satisfied with it
You must get approval from your local Environment Agency officer if you want to use previous construction proposals. You will need to send your local Environment Agency officer a cell layout drawing and get their approval for these construction proposals before any construction takes place.

You must construct the cell to the agreed design. Only very minor changes are allowed. Very minor changes mean changes that would not have any impact on the performance of any element of the design. You must get approval from your local Environment Agency officer if you want to change the construction proposals.

Get approval for landfill infrastructure

When the Environment Agency has granted your permit, you must not construct any landfill infrastructure until you have submitted your construction proposals and CQA plan to your local Environment Agency officer and they have approved them.

You must get approval from your local Environment Agency officer if you want to use previous construction proposals. You will need the approval for these construction proposals before you start construction.

When you have completed the construction of the landfill infrastructure, you must submit a CQA validation report for the works to your local Environment Agency officer.

If pollution controls are needed to prevent an incident or accident you can start construction without the Environment Agency’s approval. You must submit the construction proposals to your local Environment Agency officer as soon as practicable.

Building your landfill before permit approval

It is strongly recommended that you do not start to construct your landfill before you are granted a permit. If you do this, it may affect the approval and validation process.

If you do start building your landfill before you are granted a permit, the Environment Agency may visit the site during construction to establish a record of the works. This will include photographs and notes.

The Environment Agency may charge you for visits to your site before it determines your application. This is the enhanced pre-application advice service (https://www.gov.uk/guidance/get-advice-before-you-apply-for-an-environmental-permit).

During pre-application discussions and site visits, the Environment Agency will offer advice on, but not approval of:
- liner design
- installation methods
- materials installed
This is to avoid prejudging the outcome of your permit application.

You must follow our waste recovery guidance (https://www.gov.uk/government/publications/deposit-for-recovery-operators-environmental-permits/waste-recovery-plans-and-deposit-for-recovery-permits#waste-recovery-test) if you want to:
- record the waste you use in your engineered structure as recovered waste
- create a sub-base for the geological barrier
The Environment Agency will include the recovery of waste as a separate activity in your permit.

Developing new methods and materials

The Environment Agency encourages you to develop and use new methods and materials where it results in improved or equivalent environmental protection.

When new methods or materials do not meet established engineering standards, you must provide the Environment Agency with evidence to support their use. The amount of evidence must be proportionate to the risk of failure of the proposed new method or material.

Evidence includes:
- a literature review
- laboratory testing and modelling
- field trials
- site comparisons
- research and development projects
The Environment Agency will assess the evidence you provide. You need to allow time in your permit application, or when you submit your construction proposals, for the Environment Agency to assess any new proposal and for any subsequent negotiation.