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AD crop-residue feedstock - is an Environmental Permit required?
The Environment Agency, in response to questions relating to whether certain AD feedstocks are waste or not, have this week published a Briefing Note to confirm the status of 'crop-residues'. In some circumstances the feedstock being sent to the AD plant by the producer are 'by-products' (not waste) and therefore plants only using such feedstocks do not need an Environmental Permit.
These circumstances are:
- Misshapen, bruised or undersized fruit and vegetables separated out, on the farm or in a pack-house, as being unsuitable for sale as food or consumption;
- Parts of fruit and vegetables such as leaves, roots and topping that are removed as part of the processing for sale. This may be in a pack-house or at a farm;
- They are not mixed with or contain any wastes;
- They are suitable for use and certain to be used as a feedstock for AD (irrespective of whether the AD plant is on a farm or not);
- They can be used directly as an AD feedstock with no additional processing apart from that which might be reasonably expect of energy crops. For example, maceration would be OK, whereas de-packaging or pasteurisation would not;
- Their use in AD will not lead to overall adverse environmental or human health impacts. NB: This needs to take account of any storage and processing prior to AD, the AD process itself, as well as the subsequent storage and use of the biogas digestate produced. The crop residues will, for example need to be disease free and not contaminated with pathogens.
If you are an operator with a Permit and meet the above circumstances, and no longer intend to accept waste at your AD plant in the future, you can apply to surrender your permit.
If you feel you qualify and wish to surrender your permit or if you wish to discuss your options with somebody please contact us.
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Waste or Product?
You may be aware there are a series of quality protocols available to the industry to achieve a specific standard to enable treated wastes to be reused as a product. There are now 12 quality protocols ranging from Bio-methane to Tyres.
A Quality Protocol checker webtool available for compost and aggregates has been available since the spring of this year, having been developed by the EQual Programme. It aims to support and encourage the use of products made from waste and provides supports to businesses, resulting in a streamlined, consistent regulatory approach and improved market confidence in using end of waste materials.
See the latest EQual newsletter here.
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Recent Planning Success
Since our last newsletter, we are very pleased to announce that planning permission has been granted for three large projects that we have been working on this year. For Tamar Energy, South Tyneside Council granted permission for a 70,000 tonne, 3 Mw AD plant within the green belt at Wardley Colliery. For Green Waste Energy Inc, Wiltshire Council granted permission for a 150,000 tonne facility to take residual waste, recover the 50% fraction of recyclates and to use the balance as a bio-fuel for a pyrolysis plant producing 11.5 Mw of electricity. For Recycle Southern, West Sussex County Council granted permission for a Waste Transfer and Recycling Facility at Elbridge Farm near Bognor Regis.
For more news, please follow us on LinkedIn.
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Milton Keynes Expansion
Milton Keynes Council has just announced its first consultation on the updating of its forward planning policies, with particular reference its continued expansion. It is at the same time working on a Minerals Local Plan, which is also out for consultation at the moment. We are involved in both processes, so if you have any interest in land or minerals in the Milton Keynes area, we would be happy to discuss with you how your interest could be represented through the planning process.
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Mineral Operations
With the pick up in the building industry, the demand for minerals is going up, at last. If this is causing you to think about whether you have reserves for the longer term, it would be wise to ensure that you understand your chances of being able to secure future expansion or new sites. With our mineral experience, we are well placed to advise you, so please contact us for a preliminary discussion.
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Office News
Our Finance and Office Administrator, Carrie gave birth to her daughter Beatrice in July; we are hoping that Carrie will return to work next year. In the meantime we have recruited the services of Claire, to look after our finances and office management. Therefore, if you have any financial queries, please contact Claire.
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