

Standard rule permitting in marine licensing
SRP requires an applicant to adhere to a list of standard conditions associated with a particular activity, rather than requiring bespoke case-officer interaction.
ABPmer was commissioned by the Marine Management Organisation to explore the potential for integrating ‘Standard Rule Permitting’ (SRP) into the fast track marine licensing regime. The system of SRP is already used by the Environment Agency and is part of the Government’s better regulation agenda. This requires the applicant to adhere to a list of standard conditions associated with a particular activity, rather than requiring bespoke case-officer interaction.
The project researched the suitability of applying standard rule permitting principles into the existing fast-track marine licences. Including: Maintenance of Existing Structures; Disposal of Low Volume Dredged Material; and Minor Removals. The work focused on the management of risk associated with these licensable activities. To ensure that an SRP process provides appropriate conditions to protect the marine environment, promote marine safety and conserve built heritage, each activity was considered through the application of a source-pathway-receptor approach. The resultant risk allowed various licensable activities to be scoped into, or out of the process.
The project concluded that the SRP approach could be adapted to a range of low risk licensable activities, including Minor Removals and Maintenance of Existing Structures. If adopted the applicant would see a benefit through more rapid licence processing, based on a simple submission of the activity’s method statement, and the MMO would see a time saving through a reduction in the volume of applications needing case-officer time. It was also concluded that the SRP process did not sufficiently address the risk associated with the disposal of dredge material, with further site-specific consideration needed in most situations. A recommendation for moving this issue forward considered that a review of the Maintenance Dredging Protocol process would facilitate the use of an SRP approach – a number of estuaries already have an MDP – but some adaption of the MDP would be needed before this could be used to its full potential.
For more information, email Natalie Frost, or call +44 (0)23 807071 1850.