CTE and CTO
Consent to Establish (CTE) is taken before you build. It is the Board's permission to set up or expand at that site, for that activity.
Consent to Operate (CTO) is taken once the unit is built and before you start production. This is the one that has to be renewed.
What happens often is this. A unit takes the CTE, builds, starts production under pressure, and the CTO gets left for later. Nothing goes wrong immediately, so it stays forgotten. It comes up at an inspection, or when a bank does due diligence, or when another department asks for it.
Your category decides most of it
The Board sorts units into Red, Orange, Green and White categories by how much they pollute. Your category sets the level of scrutiny, the conditions attached, the fee, and how long the consent stays valid.
Consent to Operate is commonly valid for one to five years depending on category. Higher categories renew more often. Getting the category right at the start matters. Understate it and your consent will not cover what you actually do. Overstate it and you pay for scrutiny you did not need.
What we handle
- Working out your correct category
- Consent to Establish for new units and for expansion
- Consent to Operate, including first applications after construction
- Renewals, tracked before they expire
- Amendments when the process, capacity or product changes
- Hazardous waste authorisation where the activity needs it
- Replying to objections and attending inspections
Where these applications go wrong
The same problems come up again and again. Effluent and emission details that do not match the real process. A site plan that does not match the building. Capacity stated one way here and another way in the factory licence application. Missing consent from a previous owner where the premises changed hands.
Because pollution consent is needed before the factory licence, a mistake here does not stay in one place. It holds up everything after it.
Common questions
Which comes first, CTE or CTO?
CTE comes first, before construction or expansion. CTO comes after the unit is built and before production starts.
How long is a Consent to Operate valid?
It depends on your category. One to five years is the usual range, with higher categories renewing more often. We track your expiry and remind you in advance.
What are Red, Orange, Green and White categories?
They are the Board's classification by pollution potential. Red gets the closest regulation, White the least. Your category affects scrutiny, fees, conditions and validity.
We are operating without a CTO. What should we do?
Talk to us before an inspection rather than after. It is usually fixable. What it takes depends on your category and how long the unit has been running.