EA consultation on Landspreading and Digestate storage - Initial feedback from members
Following pre-consultation discussions with ORG, the EA has released a consultation (No. 14) on Standard Rules 2010 No. 4, 5, 6 and 17, which covers digestate storage and landspreading of non PAS compost and digestate. More details on the consultation are HERE.
The Environment Agency are consulting on their proposed amendments to mobile plant standard rules and risk assessments authorising the spreading of waste on land for agricultural and ecological benefit. SR2010 No4, No5 & No6.
7 proposed changes to standard rules:
- Storage of waste prior to spreading
- Deployments for greater than 50ha
- Prohibit spreading in Groundwater Safeguard Zones
- Restrictions on spreading in adverse conditions
- Update list of acceptable wastes, add new wastes
- Pre-notification of intention to spread
- Amendments to definitions and wording
ORG has run two workshops with members in London and Leeds to garner the views of members and identify any issues with the proposals. There have been a number of issues highlighted but the initial feedback from members detailed the main concerns:
1. There is a significant difference between the requirements for spreading waste versus a product material (PAS). Whilst this is understandable there is concern that with more material being spread as ÂproductÂ that this may result in pressure for the EA to exert more regulatory control over ÂproductÂ status material. In addition, any future changes to the end of waste position may result in more material being spread as ÂwasteÂ and the additional controls making this not a viable option.
2. The commercial implications of some of the proposals donÂt seem to have been considered properly and some of the financial impacts are considerable.
3. A reduction in the volume of non-stackable waste/deployment from 3000 tonnes to 1250 (the EA want to differentiate between stackable and non-stackable materials) is not justifiable and not welcome with some members suggesting that limits should be related to deployment requirements.
4. The proposal to prohibit spreading of high readily available Nitrogen wastes (HRAN) such as digestate on groundwater safeguard zones. HRAN is any material that > 30% RAN which includes all digestate but not compost. For some operators this is a major issue and as it is already covered with the NVZ regulations it was felt that this could lead to double regulation and is not in line with other agricultural material which could have the same pollution potential.
5. It was felt that imposing a storage limit of six months on temporary storage facilities in order that there is greater investment in ÂpermanentÂ storage sites is more likely to result in material being spread at less than optimal times and there is a lack of evidence to suggest that shorter storage has less risks.
6. A requirement to pre-notify the agency in advance(48 hrs) of any spreading activity may be an issue for some operators.
The EA are proposing to amend the standard rules and risk assessment for the storage of digestate from AD plants. SR2010 No 17.
Key proposed changes include:
1. A requirement for containers used to store non-stackable wastes to be constructed in accordance with CIRIA 126
2. Any high readily available nitrogen wastes such as digestate must be stored with ÂcoversÂ on the storage tanks to inhibit ammonia volatilisation.
3. Different wastes must be stored separately on site
The most onerous of the above requirements was felt to be the requirement for construction of storage tanks in compliance with Ciria 126 as this may be very costly for industry to comply with and result in existing satisfactory storage tanks no longer acceptable for use.
Please Send your comments for collation, review and inclusion in REAÂs response to the EA to Jeremy by the end of February (earlier if possible). We aim to circulate our draft response early March prior to submission to the EA.
Submit your comments to EA:
o by downloading the EAÂs response form, completing and emailing it to SRCN14@environment-agency.gov.uk (postal address also provided on the form)
EA deadline: Friday 20th March 2015