Update from ADBA’S Technical Support Manager following the Biowaste Regulatory Forum

Last week I attended the Biowaste Regulatory Forum, which brings together Defra, the environmental regulators and industry bodies. Unfortunately, due to purdah Defra did not attend but the EA and NRW had representatives.

The main points discussed at the meeting were:

Standard Rules Permits Consultation

ADBA will be directly contacting members who have expressed an interest in the Standard Rules Consultation, posting reminders of this call for evidence, releasing ADBA’s internal review of permit changes and organising a last chance to provide input in early January at a meeting of the Training, Safety and Environment Management Working Group.

Initial feedback from the Environment Agency (EA) was that the consultation does not mean completely re-engineering of infrastructure. In some circumstances the implementation of better standards of processing, updating management systems and planned preventative maintenance may be suffice.

Contingency plans for waste storage

Matt Davis from the Environment Agency (EA) expressed concerns about contingency plans for waste storage due to adverse weather. The EA is reviewing the ‘Contingency Plans for Waste Storage’, which states that relying on the ability to spread to land at all times of the year is not a sustainable management solution.

The EA would like to have feedback on whether this is useful and if it should be seen on gov.uk.

PAS110 materials for seeding and feeding during commissioning

The EA explicitly stated at the meeting that any plants wishing to commission and feed prior to receiving a permit can only use non-waste feedstocks and the derived digestate. The also reiterated that sewage sludge cannot be used as a seeding material as well as AD Quality Protocol certified digestate.

This has the potential to become a high-profile issue and hopefully raising this issue will stop this becoming an industry wide concern. For the full briefing on this please contact me directly.

Quality Protocol Review

In the absence of Richard Fairweather, the QP review lead, the EA collectively informed the group that a review of the first three Quality Protocols was complete. This includes compost and anaerobic digestate. A review is carried out to determine whether an actual revision of the standard is needed, so does not necessarily mean there will be a change. There will of course be opportunities for industry to input their views during the call for evidence that will be released on the 13th December due to election being on the 12th December. Targeted questions will be released in the call for evidence that will be open longer than the stated 6 weeks. It will close on the 31st January due to the festive period.

If support for the QP is withdrawn and there is no willingness from industry to have the QP revised then it will open up individual end-of waste positions, the material could also be spread using mobile plant permits and deployments. Or alternatively, the material could be sent to any other suitably permitted/exempt facilities.

Other topics discussed

The meeting also included sections on the EA Sludge Strategy, EA Plastics Update, Farming Rules for Water, NRW’s update and the cost implications for the sector implementation of BREF.

If you have any questions about the forum or any of the above please contact me on sam.hinton@adbioresources.org.