What does a Regulation 61 notice mean for your airport operations?

Published: 20 October 2026

Over the last two years, the Environment Agency has issued Regulation 61 notices to around 25 UK commercial airports. Each one comes with a fixed deadline and requires the airport to survey, screen, sample and report on what’s in its surface water, groundwater and trade effluent discharge, including PFAS, hydrocarbons, de-icer and other pollutants.

That’s a long way from environmental compliance as a report, a permit or a line in the sustainability strategy, and it affects operations as much as the environment team.

The notices are part of a wider regulatory programme, much of it aimed at UK airports. Defra published the UK’s first national PFAS Plan in February 2026, and the Health and Safety Executive has consulted on restricting PFAS in firefighting foam altogether, with a decision expected in 2027.

Why is the Environment Agency is focusing on airports?

Most of the environmental risks the Environment Agency regulates can be found at an airport, and often on the same site.

Fire training areas and legacy Aqueous Film-Forming Foam (AFFF) use has left PFAS in the soil and groundwater at sites across the country. Fuel farms, tanks and pipework carry a constant hydrocarbon leak and spill risk whilst un-maintained drainage networks are often decades old and badly mapped but still expected to carry surface water, and any PFAS or hydrocarbons in it, safely to a discharge point that meets consent conditions. Add flood risk, biodiversity obligations and the environmental scrutiny that comes with runway and terminal expansion, and it’s clear why airports are treated as a priority sector.

What this means for airport operations

Airports may be inclined to treat a Regulation 61 notice as a compliance obligation for the environment team to manage, however most of the failures that trigger enforcement action also disrupt day-to-day operations.

A blocked or undersized drain can breach a discharge consent and flood an apron, and a leak at the fuel farm is both a pollution incident and an unplanned shutdown while it’s contained and investigated. Lagoons are a particular risk in winter, when a cold snap can send more de-icing runoff into them than they can cope with, and operations can’t simply stop while the problem is dealt with. In practice, the drains, tanks and lagoons that matter for compliance are the same assets that keep an airport running.

A well-run environmental compliance programme gives airports three things:

Continuity: Planned maintenance on drainage, tanks, interceptors and lagoons prevents the failures that close aprons or trigger an emergency response.
A defensible position with regulators: Responding to a Regulation 61 notice, or any permit review, is much easier for an airport that already has monitoring data, a conceptual site model and a maintenance record.
Room to grow: Every new stand, hangar or terminal project is now assessed for contamination, drainage capacity and ecological impact before it gets consent. Airports that already understand their environmental baseline move through planning faster than those that find problems during construction.

What this looks like day to day

At a well-run airport, environmental compliance is an ongoing programme with a handful of consistent elements: a drainage network that’s understood and has a maintenance record, a PFAS strategy that goes beyond one round of testing, fuel infrastructure managed on a planned lifecycle, continuous monitoring of lagoons and surface water, and de-icing operations designed around the drainage network’s capacity.

An airport doesn’t need its own in-house environmental consultancy to do this. Environmental risk can be managed the same way engineering and estates teams manage any other critical asset, with a clear owner and a record of the work.

Looking ahead

Regulatory pressure on UK airports is not going to ease off. We’re seeing PFAS regulations tighten, discharge consents come under closer review and expansion plans face more scrutiny than they have in years. Airports that plan, maintain and monitor their environmental infrastructure are better placed to keep operating without interruption, and to give regulators the evidence when they ask for it.

We work across the aviation sector helping airports build this kind of programme, from Regulation 61 responses and PFAS management to drainage, fuel infrastructure and lagoon monitoring. If you’d like to know where your airport stands, get in touch.