Consultation outcome

Standard rules consultation no 20: revision of standard rules permits for biowaste treatment – summary of responses

Updated 2 February 2021

This 20th consultation on standard rules proposed revisions to the rules sets for biowaste treatment, including composting and anaerobic digestion (AD) activities.

The reasons for needing to revise the standard rules include to:

• fully implement the best available techniques (BAT) reference documents (BREF) and BAT conclusions by 2022 – as laid out in the waste treatment BREF for all waste activities detailed under the Industrial Emission Directive (IED)

• address discrepancy in design and construction standards across the sector

• improve performance and minimise the impact on the environment and local communities by ensuring all operations implement all available techniques – includes removing ambiguity by clearly stating the required standards of performance

• ensure the sector increases its contribution to the circular economy by being the central player in food and organics recovery – producing high quality and marketable fertiliser to replace chemical fertiliser and soil improver

• deliver against the key objectives in government’s clean air strategy and 25 year environment plan

• continue to contribute to reduction of climate change impacts by improving soil quality, capturing and storing carbon and producing energy from AD

The Environment Agency must ensure:

• it limits any negative impacts on human health, communities and the environment
• emissions are controlled, such as odour, bioaerosols and ammonia
• there is no risk to water, air, soil, plants or animals

1. How we ran the consultation

We ran a consultation in 2018, ‘Biowaste permits: review to improve environmental outcomes’ to help us prepare for this consultation. See the response document published to the GOV.UK website.

This consultation follows on from that review and proposes the changes to the rules. It ran for 18 weeks from 21 October 2019 to 28 February 2020. We invited you to comment using our Citizen Space online consultation tool. We asked 11 questions.

We held webinars and face to face meetings with industry to explain our proposals. We provided evidence to support the changes we proposed.

We want our proposals to achieve the best environmental and sustainable outcomes.

We would like to thank all the respondents for their time and contribution to this consultation. We have reviewed all the comments and suggestions received.

2. About you

Q1. Are you responding as an individual or on behalf of an organisation or group?

We had 45 responses to the consultation:

• 15 from site operators (one response represented multiple operators)
• 9 from trade associations
• 8 from water companies
• 2 from consultants
• 10 from local authorities, including the Association of Directors of Environment, Economy, Planning & Transport and the Local Authority Recycling Advisory Committee
• 1 from a government body

There were no comments from members of the public.

Q2 Keeping up to date

We acknowledged all respondents who gave us their contact details. This document provides our responses to the comments and suggestions raised.

We will now make changes to the relevant standard rules permits. We will set out the measures and standards we expect to ensure improved environmental performance. We also think our proposals offer better protection and assurance for operators.

We are planning to consult on proposed amendments to the standard rules permits for storing waste before spreading it to land and mobile plant permits.

Q3. Can we publish your response?

We were given permission to publish most responses. Four respondents asked us not to publish their comments. This gives visibility on all the points raised and allows us to set out in full how we intend to deal with them. See the list of respondents

Q4. Please tell us how you found out about this consultation?

Respondents found out from:

• the Environment Agency – 34
• another organisation – 11
• an organisation or group or club you’re a member of – 2
• a press article - 3 (including through the GOV.UK website)
• social media such as Facebook or Twitter – 1
• a meeting you attended – 0
• other (please specify) – 0

Some respondents found out from more than one place.

Q5. Do you agree with our approach to revise the standard rules sets?

The responses were:

• agreed – 14
• disagreed – 29
• do not know – 2
• no answer – 1

Q6i. Which proposals do you not agree with?

The main concerns respondents raised were, the:

• requirement for strict input limits on plastic contamination
• requirement for construction standards for existing sites
• cost to water industry applying BREF and BAT to facilities treating over 100 tonnes of waste per day
• removal of physical chemical treatment of sludge
• withdrawal of duplicate standard rules sets
• control of emissions and the requirement to cover ammonia and odour feedstock and digestate
• cost of meeting BREF and BAT (generally)
• need for the use of more and clearer operating techniques as permit conditions to ensure best practice

Q6ii. Why do you not agree with proposed changes?

Detailed responses were provided. We have summarised the concerns raised and our responses to them.

The next sections summarise the comments received and our response to specific revisions to the standard rules permits.

3. Withdrawing standard rules permits

We propose to remove these standard rules permits for mechanical biological treatment of waste:

• SR2008 No 18
• SR2015 No 12

Summary of responses

We received 1 response:

• agreed – 1

Our response

Only 1 operator has applied for one of these permits since 2008. We will move that operator to a more suitable non-hazardous standard rules permit. Therefore we will withdraw these permits as they are not needed.

4. Merging standard rules permits

We proposed that we:

• merge SR2010 No 15 (no longer available to new applicants) with SR2012 No 12 anaerobic digestion facility including use of the resultant biogas (waste recovery operation)

• merge SR2010 No 16 (no longer available to new applicants) with SR2012 No 10 on-farm anaerobic digestion facility using farm wastes only, including use of the resultant biogas

• merge SR2008 No 16 25kte and SR2008 No 16 75kte with SR2012 No 7 composting in open systems

• merge SR 2010 No 14 with SR2011 No 1 small scale composting operations 500 tonnes at any one time

• merge SR2008 No 19 75kte and SR2008 No 19 250kte and replace with one new permit to provide a single version for sludge anaerobic digestion at 500kte per annum

We received 15 responses:

• agreed – 3
• disagreed – 9
• neither agreed nor disagreed – 3

Summary of responses

Some respondents were concerned with our proposals to remove some existing permits. They feel this would lead to more operators having to apply for bespoke permits.

One company stated that the changes made to SR 2008 No 19 would not allow companies to treat sewage sludge by lime stabilisation. They stated that these are simple operations which have a low yearly throughput of under 25,000 tonnes or that only operate at certain times of the year. The operators stated that the move to an IED threshold will be detrimental to small businesses with no standard rules option for just lime stabilisation or co-composting sludge.

The water industry stated that they were unable to use these standard rules due to set back distances from sensitive receptors, for example water courses.

Trade bodies stated that existing permit holders will need notifying and given time to meet new standards.

Another respondent believed there may be a problem if a standard rules permit is not replaced with a like for like. Smaller scale AD will have been built to the standards of the time. They requested us to state how many sites will be affected.

One comment stated that serious incidents are decreasing therefore the changes are disproportionate.

Our response

We currently have 21 standard rules permits available for biowaste treatment. This is partially because when we introduced new versions of standard rules permits in 2010 and 2012, we maintained the previous versions for existing operators. New applicants applied for the new versions. In retrospect, we should have replaced the existing standard rules permits with the new ones. This has meant some versions are slightly different to others.

Since 2010 we have also seen the AD industry develop sites with more complex operations. In some cases the design and construction may have been to unsatisfactory standards. We feel that our permits must reflect the measures and standards necessary to control the risk of pollution. We have been working with industry on how to achieve this since 2018, providing the opportunity to present alternative proposals.

We did consider removing all standard rules permits for biowaste treatment and reverting to the need for a site specific assessment to recognised standards. However, we have instead chosen to amend the permits, to include clear and the more stringent operational standards required. We will review compliance and the number of pollution incidents over the coming years to assess if these measures have been sufficient to improve compliance and operating standards. Existing operators who are currently compliant will already be able to comply with the revised standard rules permits. Normally operators are given 3 months to comply with new versions of rules sets. However, we have allowed additional time for existing operators to achieve compliance with baseline standards or present a risk based re-evaluation and assessment.

For existing permit holders we will move permits over to a like for like rule set as an administrative variation free of charge. Or where necessary operators can apply to be moved to a bespoke permit.

With the implementation of the IED in 2014 operations with a treatment capacity over 75 tonnes per day for composting and 100 tonnes per day for AD are required to operate under an installation permit. Therefore the waste tonnage limits in the previous standard rules permits (2008 and 2010) are no longer valid.

We are pleased to confirm that we have seen a decrease in serious category pollution events. This is as a result of:

• significant preemptive auditing of AD facilities and taking regulatory action where necessary – this required additional funding for resourcing enforcement action
• sharing root cause analysis of incidents with industry
• focussing on operator knowledge and competence
• a review of Environment Agency biowaste training and training delivery for our staff
• installations implementing the waste treatment BREF and BAT conclusions

Our 3 year audit campaign saw a significant reduction in the number of serious incidents. We followed this up with audits on containment and accidents and emergencies. These showed deficiencies in infrastructure and poor or poorly executed environmental management systems (EMS). We think these are the root cause of poor compliance and the number of incidents.

The number of category 1 and 2 incidents do not provide the full compliance picture of the sector. Although these have decreased, the sector remains one of the most significant contributors to amenity impact and complaints from local communities.

We have identified significant risk from pollutants such as ammonia which we must take responsibility to reduce.

This confirms the need for us to amend the standard rules permits as proposed.

Here we provide the number of operators affected by the changes.

Open windrow waste facilities (standard rules permits)

SR2008 No 16 25kte and 75kte: composting in open systems (not available to new applicants) – 18 existing operators.

SR2012 No 7: composting in open systems - 6 existing operators.

This means a total of 24 permits will operate under SR2012 No 7 open windrow waste compost sites.

Open windrow installations

SR2012 No 8: composting in open systems – 3 existing operators

There is no change to the permit reference but we will amend the rules.

In-vessel composting treating animal by-products

SR2008 No 17 75kte: composting in closed systems (in-vessel composting no longer available since 2013) – 2 existing operators

SR2012 No 3: composting in closed systems - 2 existing operators

This means a total of 4 permits will operate under SR2012 No 3.

In-vessel installation

SR2012 No 4: composting in closed systems – 0 operators

Small scale composting

SR2010 No 14: 500t composting biodegradable waste – 23 existing operators

SR2011 No 1: 500t composting biodegradable waste (in open and closed systems) – 13 operators

This means a total of 36 permits will operate under SR2011 No 1 in open or closed systems

Anaerobic digestion – waste

SR2010 No 15: anaerobic digestion facility including use of the resultant biogas – not available to new operators – 2 existing operators

SR2012 No 12: anaerobic digestion facility including use of the resultant biogas (waste recovery) – 5 existing operators

This means a total of 7 permits will operate under SR2012 No 12.

On-farm anaerobic digestion

SR2010 No 16: on-farm anaerobic digestion facility – 12 existing operators

SR2012 No 10: on-farm anaerobic digestion facility using farm wastes only, including use of the resultant biogas – 88 existing operators

This means a total of 100 permits will operate under SR2012 No 10.

On-farm anaerobic digestion installation

SR2012 No 9: on-farm anaerobic digestion using farm wastes – 7 existing operators

There is no change to this permit reference.

Anaerobic digestion installation – waste

SR2012 No 11: anaerobic digestion facility including use of the resultant biogas – no permits

Waste water treatment works (WWTWs)

SR2008 No 19 75kte and SR 2008 No 19 250kte – these WWTWs will move to installation permits.

The biological treatment of sewage sludge at more than 100 tonnes per day is now regulated as an installation. The current standard rules do not align with the waste treatment BREF and BAT conclusions so without revision they would be redundant and all operators would be moved to bespoke permits. These replacement standard rules enable an as yet unknown number of operations to continue to operate under standard rules. The remainder will move to bespoke permits.

Where operators wish to compost urban waste water treatment sludge they can operate under the open windrow or in-vessel composting standard rules permits.

5. Location of sensitive receptors

We proposed to change some of the location criteria for the standard rules permits in this consultation.

5.1 Inclusion of marine conservation zones

We received no responses to this.

5.2 Specified air quality zone

We proposed that we would not permit sites in air quality zones.

We received 6 responses:

• agreed – 0
• disagreed – 3
• neither agreed nor disagreed – 3

Summary of responses

Water companies asked for operators in an air quality management area (AQMA) to be given time to apply for bespoke permits.

The introduction of the sites not being allowed to operate in AQMAs will reduce the availability of standard rules to a number of operators.

Our response

All AD permits already exclude operations within an AQMA. AQMAs provide protection against specific named pollutants, oxides of nitrogen and sulphur and particulate matter. Evidence shows the risk to human health of these pollutants – they are mainly in urban and highly polluted areas. An operation will only be excluded from using a standard rules permit if the locality is a designated AQMA. The impact on composting sites will only reflect pollutants like PM2.5 particulates.

We will give existing permit holders operating in specified air quality zones 3 months to apply for a bespoke permit. They should seek pre-application advice. To find out if your operation is in an AQMA see Department for Environment, Food and Rural Affairs (Defra) UK AIR website.

Water companies operating under SR2008 No 19 will no longer be able to do so if the site is within an AQMA. There is a comprehensive program to require all sludge biological treatment operations to have installation permits. This begins in April 2021 and runs until summer 2022. Any water companies with sites operating under existing SR2008 No 19 permits within an AQMA can continue to do so until the site comes up for review at which point a bespoke permit application will be required. This gives operators between 6 and 24 months to gather evidence to support their application.

5.3 Groundwater source protection zones (SPZs)

Most of our standard rules permits exclude sites located within groundwater SPZ 1 and 2. Some permits only stated SPZ 2. We have amended all permits to exclude sites located within groundwater SPZ 1 and 2.

We received one response who disagreed with this proposal.

Summary of response

Existing operators may no longer be able to use standard rules permits if they operate within a SPZ 1 or 2. This is the fault of the Environment Agency and not the operator.

Our response

Operators already excluded by SPZ 2 would automatically have been excluded from SPZ 1. This is for clarification purposes only.

5.4 Definition of nearest sensitive receptor to include dwellings

We received 5 responses:

• agreed – 0
• disagreed – 5
• neither agreed nor disagreed – 0

Summary of responses

One respondent wanted to know if families living on site, such as a farm were defined as sensitive receptors when they are working on-site.

Respondents also stated that exclusion (as they already stand) means that an ecological survey would be required which is at odds with the light touch approach.

It was felt in some cases that set back distance of ‘10 metres of any water course’ would be restrictive to the water industry. This is because of an inherent requirement for treatment assets to have proximity to a permitted release point to controlled waters.

The water industry also stated that they have several locations where sewage sludge cake storage is on the boundary of the site and within set back distances of sensitive receptors.

Our response

The definition of sensitive receptor has not changed and is set out in the interpretation section in all our standard rules permits.

People working at the site are covered by health and safety legislation. Families and other residents (who are not employed) are not protected by this legislation. They should therefore be given the same protection as other members of the population. This is the position we have held for over 10 years and we will apply it to all sites where there is risk from process emissions to air. Dwellings are subject to the exclusion distance as they are considered sensitive receptors. We will amend our application forms to ensure this is clear.

To use a standard rules permit stacks from the combustion of biogas must be located more than 200m from a sensitive receptor. All stacks must have an effective stack height of 3m. Effective stack height is defined in the interpretation section of our standard rules permits and in other guidance. Stack dispersion modelling tells us that there is a ground level impact on sensitive receptors from these emissions within 200m of the stack. This set back distance has been in place since 2010.

In terms of ecological assessment, this is not required as designated areas are already listed in standard rules permits. If there is a change to the distance from the site to a designated area, then the operator must apply for a bespoke permit.

Operators that cannot comply with standard rules have the option of applying for a bespoke permit.

6. Waste treatment BREF and BAT

If you operate an installation you will be required to meet BAT Associated Emission Limits (BAT AELs). Existing operations must meet BAT AELs by 2022. New installations must meet the standards from the start of operations.

We proposed to amend the operational techniques to reflect this requirement.

We received 12 responses:

• agreed – 1
• disagreed – 8
• neither agreed nor disagreed – 3

Summary of responses

One respondent suggested that the BAT AELs are values rather than limits. They stated that BAT is a compromise of what is realistically achievable at a viable cost rather than asking for solutions that are unaffordable and which will never be implemented. The Environment Agency needs to ensure consistent but pragmatic application of BREF and BAT. They also stated that the implementation of BAT may have implications to existing contracts through change of law clause that may require resolution as part of adopting new standards.

The industry also stated that they do not propose to go beyond the waste treatment BREF and stated that operators’ EMSs should be sufficient to reduce the risk of pollution.

Industry stated that there needs to be a level playing field between standard rules permits and bespoke permits.

The water industry indicated that the timescales for the implementation of waste treatment BREF and BAT conclusions would be problematic. Also that the Environment Agency have only recently concluded that the water industry with AD plants on sewage treatment works (STWs) are subject to permitting requirements under the IED (as implemented through the Environmental Permitting Regulations). This issue has been raised by Water UK and it is understood the Environment Agency are exploring possible extensions to this 2022 timescale with Defra.

The water industry commented that existing AD plants on sewage treatment works, their location, current operations and physical issues all must be considered and taken into account otherwise the proposed standard rules will not be applicable. If AD plants on STWs are unable to benefit from the revised standard rules, it will considerably increase the costs for the water industry.

One respondent expressed concerns about the monitoring requirements required by BREF and in particular waste treatment BAT 34. They thought that the odour limits were very low, but stated that they saw the surrogate use of ammonia and hydrogen sulphide (H₂S) as a positive step. This is because odour is prone to significant monitoring inaccuracies and therefore unreliable to use for enforcement with an emission limit. However, they pointed out that the H₂S limit is not prescribed by BREF and that the correlation between H₂S and odour only appears to work when odour concentrations are high. They proposed the use of Drager tubes as a process control monitoring method (inlet and outlet) to verify the % reduction to show the biofilter is performing well. They went on to state that they were sceptical about using monitoring for quantitative compliance with a numerical emission limit for biofilters.

Our response

Implementing BREF and BAT conclusions are mandatory. The AELs are presented as a range of limits in the BAT conclusions. They can be met using one or a range of BAT techniques. We will keep limits under review when considering sensitive locations.

Where necessary we can amend standard rules permits, for example if we consider standards need raising to reduce risk or to provide further clarification. If operators cannot take advantage of our standard rules permits they can apply for a bespoke permit. For these we will carry out a site specific risk assessment.

Waste treatment BAT 34 requires abatement for channelled emissions and operators are given a choice of techniques and associated emission monitoring. There are other requirements under BAT 3 to fully characterise all gas stream emissions and take corrective action. This may allow a demonstration of proxy correlation to institute cheaper or more appropriate monitoring techniques and reporting.

The IED (as transposed by the Environmental Permitting Regulations) requires us to review and update relevant permits within 4 years of the publication of any BAT conclusions. This duty applies to any BAT conclusions published by the EU before the end of the EU transition. Thereafter, BAT conclusions will be published by the Secretary of State if required. We are not yet certain what form the UK BAT conclusions (if they are amended) will take or how the development and publication process will be managed, but indications are that a similar approach will be maintained. We will review our standard rules permits if necessary.

Water industry concerns about the location and established operating practices are noted. However standard rules are developed on a risk basis rather than by industrial sector. If water industry sites pose a higher risk then we accept that these sites will need bespoke assessments. It would not be appropriate or equitable to adopt different standards for the water industry simply to enable greater take-up of standard rules permits.

We recognise that a large number of water industry sewage sludge digesters will be newly permitted within 12 months of the August 2022 BREF compliance deadline. We will continue to explore the viability of and mechanisms for extending compliance deadlines beyond this date.

We will be reviewing all installations and waste bespoke permits so the operational and environmental outcome requirements will be the same.

7. Design and construction of critical infrastructure, secondary containment and drainage systems

We want existing and future operations to meet a recognised design, build and maintenance standard for all site infrastructure. We advocated CIRIA standards. We proposed that:

• a qualified civil engineer assesses the site
• the engineer validates the sites containment as meeting CIRIA standards

An assessment would confirm the infrastructure is fit for purpose and can retain all polluting material in the event of failure. We recognise that the assessment may show the site cannot meet CIRIA standards. The operator will have the opportunity to adapt their site, present alternative measures if need be and show how they can manage the risk. We do not require the operator to build secondary containment, unless it is absolutely necessary to mitigate loss of containment. Most AD operators already have secondary containment as shown by our major AD audit, but it should have an independent inspection and assessment. Infrastructure may need to be upgraded if the necessary protection is not provided.

We estimated the cost of a chartered engineers report to be between £1,000 and £2,000. This was reconfirmed by chartered structural and civil engineering companies. This is the least expensive (and is a risk based approach) for the biowaste sector – this is in line with other waste sectors, such as landfill. They are already required to validate their sites by a qualified chartered engineer.

We also proposed secondary containment for underground tanks across the standard rules permits. This is to ensure a level playing field across all permits, some of which already have that requirement.

We received 11 responses:

• agreed – 0
• disagreed – 9
• neither agreed nor disagreed – 2

Summary of responses

Industry as a whole replied that retro-fitting sites will be expensive and if they are extremely low risk sites secondary containment may not always be necessary.

Making sure a lagoon meets CIRIA standards can be expensive and technically difficult depending on location, age and existing infrastructure. In the past the ‘How to comply’ guidance did not lay out standards when older permits were issued. The industry felt that applying CIRIA 736 standards is not a ‘light touch’ approach.

Other respondents stated they did not think that they would meet CIRIA standards and wanted to know what would happen if the site did not.

One respondent asked what the ‘equivalent standards’ stated in the consultation were and that these needed to be set out in guidance to ensure consistency.

Sludge treatment companies undertaking physico-chemical treatment with short residence times and no storage of liquors felt CIRIA 736, for bund designs, was not appropriate, was excessive and would cause serious financial impact in low risk areas. They went on to question the need for secondary containment being required for underground tanks.

The water industry estimated that upgrade to meet CIRIA standards would be £9 million per site. The water industry stated that this would conflict with the AMP7 deadlines 2025 to 2030.

Other water companies wanted to ensure that they can use their own qualified civil engineer to satisfy the requirement for an assessment and validation of the site meeting CIRIA standards. They added that if a third party is insisted upon, this will further increase costs.

Our response

The majority of responses received referred to the conditions and requirements already set out in our standard rules permits. Operators who cannot meet those conditions and limitations should not be operating under them. They can discuss any issues with their local Environment Agency teams and either take steps to manage any risk or apply for a bespoke permit. We may also consider appropriate enforcement action where there is a need.

We are only consulting on the need to meet a standard. CIRIA standards are the most appropriate for new and existing sites and an independent assessment of necessary containment infrastructure will ensure all sites can meet the same standard.

Existing sites

We require a chartered civil or chartered engineer to do the risk based assessment.

We accept that some companies employ a chartered civil or structural engineer that can adequately assess the assets on site.

We have never proposed retro-fitting.

Inspecting critical infrastructure is a standard compliance practice and is included in CIRIA 736 and inspection and maintenance procedures in construction or manufacturers recommendations.

We will adopt the CIRIA standard for secondary containment. It’s based on assessing risk and mitigating the potential consequences of the primary storage failing. The Anaerobic Digestion and Bioresources Association also published a screening tool over 5 years ago to help operators assess risk – this also follows the CIRIA guidelines.

However, where CIRIA standards cannot be met and if the operator can demonstrate using an alternative standard, that meets the same or a better standard we will accept that. Sites with any identified risk or deficits that may cause pollution will be required to follow an agreed improvement plan and, or improved EMS (or both). Under this improvement plan, operators can continue to operate under the standard rules permit.

Existing lagoon storage

We have taken advice from our groundwater and contaminated land team and also consulted with civil and structural engineering companies. They advised that for all existing lagoons a risk assessment for containment as outlined in CIRIA 736 offers robust methodology to assess associated risk. The assessment is based on location and proximity to receptors. We consider this requirement is a proportionate alternative to other risk based approaches, for example withdrawing the standard rule permit or increasing set back distances.

We will require all sites to provide an accurate drainage plan. This must show how the operator will prevent the risk of polluting material leaving the site. The EMS must include a robust emergency accident plan as part of the EMS.

The requirement for a high standard of containment is fundamental to mitigation of environmental risk. Installation standard rules such as SR2008 No 19 are drafted to meet the BREF and BAT conclusions and we consider that CIRIA 736 delivers this.

Water industry concerns about costs have been explained outside of this consultation and we have expressed our concern that they are inflated. Deadlines for compliance with the BREF and BAT conclusions are independent of funding cycles and any questions of funding ought to be directed to Ofwat.

New sites

We will require new sites to get all containment validated and signed off by a chartered civil or structural engineer before operations start.

8. Technically competent operations

Our audits have found that some operations breached existing permit requirements. In our ‘Call for evidence’ consultation we asked if technically competent management attendance should be increased. Industry responded that this was only part of the issue, and that operators must be clear about how to operate competently. We proposed that we amend the operating techniques in the permit, making it clear that operators must follow our appropriate measures guidance. We will also publish guidance to explain what is required of the EMS.

We received 3 responses:

• agreed – 2
• disagreed – 1
• neither agreed nor disagreed – 0

Summary of responses

Comments received reflected a discrepancy between the legal requirements for technical competence – the qualifications required such as WAMITAB, on the job training and knowledge and attendance required. The industry stated that the Environment Agency needed to take a more pragmatic approach.

Our response

It is a legal requirement for a qualified technically competent manager (TCM) to be present on site for a proportion of the operational time. We have published guidance on the period of required attendance. The training and recognition of other approaches is developing because of the shortfalls identified with TCM training. This can only improve operator capability which is central to running an effective and safe site.

We have set out clear operational techniques in the permit, which all operators should have copies of on site.

9. Operational capacity

We consider that the total quantity of waste handled on site must be limited to the design capacity of that site. We also consider that the volume of waste in treatment vessels must not exceed the design capacity. Both these limits should be set out in the standard rules permit. In table 2.3 we proposed that:

• waste accepted on site is no more than 200 tonnes a day or exceed the designed storage capacity of the site
• the operator must make provision for storage of finished material when the landbank is not available
• there is adequate storage capacity for liquors and leachate and, or digestate (or both)

We received 4 responses:

• agreed – 0
• disagreed – 3
• neither agreed nor disagreed – 1

Summary of responses

Industry commented that at certain times operators may need to exceed capacity to allow for continuity and to prevent irregular loading. For example, to store feedstock on bank holidays and weekends.

Other comments received stated that operators should acknowledge capacity but not be restricted to it – providing they do sufficient monitoring of the biological process and infrastructure checks. The operator should be able to demonstrate full digestion and conversion of volatiles to gas through mass balance and site performance.

Our response

The volume of waste handled should not exceed operational storage and designed and permitted treatment capacity. The site must be designed so that the impact on the environment, for example odour, is managed and does not cause pollution or affect amenity. Operators, whether composting or anaerobically digesting, who repeatedly exceed their storage and, or treatment capacity (or both) experience compliance problems or in extreme cases loss of valuable assets. Bank holidays and weekends are accounted for within the waste storage times.

We will include a condition within the standard rules permit that requires limiting volumes to operational capacity.

If operators increase storage or treatment capacity then must they must assess if they need to vary their permit to become an installation. An installation as defined in the IED and Regulatory Guidance Note 2 is where treatment exceeds:

• 75 tonnes per day for composting
• 100 tonnes per day for anaerobic digestion

Operators must also have a contingency plan in place for when the landbank is not available. This must be an EMS procedure and can be on-site or off-site. In line with Silage, Slurry and Agricultural Fuel Oil (SSAFO) regulations, operators can store liquors and digestate for up to 6 months.

We will address waste storage in more detail in our appropriate measures guidance. We will have a minimum on-site storage time of 2 months in our permits. However, this does not apply to sludge permits.

10. Permitted activities

We have amended the permitted activities table for AD to include:

• gas upgrading and injection to the national grid
• digestate drying with abatement – we will remove our Standard rules permits for anaerobic digestion – point source emissions to air: regulatory position statement 192 when the revised standard rules sets are published
• allowing pasteurised, separated digestate fibre to be composted in the open with abatement or under static aeration
• provision for safe storage of raw materials
• provision for safe storage of hazardous waste, such as spent engine oil and used carbon
• the requirement to register all medium combustion plant and specified generators – the operator must notify us if they install any additional engines or generators

We have specified that SR2008 No 19 will be limited to AD.

We received 2 responses:

• agreed – 0
• disagreed – 0
• neither agreed nor disagreed – 2

Summary of responses

Respondents welcomed proposals to include activities which manage ammonia, such as digestate cooling, drying and acidification.

We received some concerns about the increased requirements of the operator and the costs of managing leak detection.

Our response

There were no objections to our proposals and we will extend our standard rules to specifically include the activities set out in the consultation. However, we will keep these activities under review.

We think these additional activities will increase the recovery rate of organic waste and will provide opportunities for the sector. However, these activities pose potential risks which operators must manage.

We will continue to include digestate drying in our standard rules but we will add a monitoring condition to assess the effectiveness of the abatement technology to included emissions monitoring. We currently believe that the risk to the environment by allowing drying under the standard rule is low if mitigation measures are in place. However, we will need operators to follow standardised monitoring. We will review the data over the next 2 years and reassess this position.

We have specified that SR2008 No 19 will be limited to AD because it is the most common form of sludge biological treatment, is listed in the IED and therefore requires an installation permit.

We believe that water industry concerns about the loss of other waste activities from SR2008 No 19 do not take into account that once the AD activities are covered by a permit the remaining activities are likely to be covered by the T21 waste exemption.

11. Waste acceptance: daily tonnages and maximum quantities

We intend to increase the daily tonnage operators are allowed to accept in the composting standard rules permits with the exception of SR2010 No 14 and SR2010 No 1. We propose to increase the daily tonnage from 75 tonnes per day to 100 tonnes per day. This allows more flexibility during peak seasons and reduces cost where for example mobile shredding plant is periodically brought on to site.

This is on the condition that the operator manages and monitors storage by adopting appropriate measures. To safeguard against unmanaged decomposition of waste before processing, we intend to include measures to manage waste in storage pending processing.

We have reviewed the waste data returns for standard rules permits. The waste received at sites is consistently below 30,000 tonnes per year. We intend to reduce the annual limit for all composting standard rules permits from 75,000 tonnes to 35,000 tonnes per year. This amount is equivalent to the threshold for installation activities.

For both installations and waste operations permits, operators will be required to restrict the tonnage to the operational design capacity as set out in the operational techniques. The operator will include this procedure in its EMS.

Operators should incur no additional cost. Those who treat over 35,000 tonnes per year should already have a standard rules installation permit.

We received 2 comments:

• agreed – 0
• disagreed – 0
• neither agreed nor disagreed – 2

Summary of responses

One respondent sought clarification of throughput in relation to IED thresholds and wanted to know if the limits are in ‘any day’ or ‘averaged over a year’.

One other commented that a reduction in annual tonnage allowances from 75,000 tonnes to 35,000 tonnes could present capacity issues at composting sites. This would mean needing additional waste facilities, so increasing costs for the local councils and their contractors. They would need to apply for additional ‘new burdens’ funding from central government to cover these changes.

Our response

The limits for the purpose of IED refer to daily biological treatment capacity not daily throughput. The treatment limits are defined in RGN 2: Definition of facility. Standard rules permits are available for installations.

Post consultation discussion with water industry suggests that 250,000 tonnes per annum limit for sludge digestion will not be sufficient for the vast majority of sites. Now the water industry is clear that indigenous sludges are included in the total it is apparent that tonnage per annum limit would need to rise to approximately 500,000 in order to see any significant uptake of standard rules. We have made this change.

12. Waste inputs and quality outputs

We want to make sure outputs are of high quality. We therefore intend to remove higher risk waste from our standard rules permits along with all 99 codes where appropriate.

We received 3 comments:

• agreed – 2
• disagreed – 1
• neither agreed nor disagreed – 0

Summary of responses

One respondent welcomes production of high quality and assured compost and digestate and agreed there is no place for 17 codes. The 17 codes can be replaced with uncontaminated wood 19 codes.

Another respondent stated that they were aware of ongoing work, led by the Wood Recyclers Association, on sampling waste wood from a variety of sources, to establish the indicative levels of contaminants within them. Whilst this work is still ongoing, the results from the wood collected at civic amenity sites shows very low levels of contamination indeed, maybe as little as 1%. This then contradicts the statement with the consultation document that “such waste wood is likely to have been chemically treated.” The respondent would support a revision to the standard rules permit that does allow waste wood specifically from civic amenity sites, to be received at organics treatment sites under the standard rules.

Our response

In 2017 we did a review of certain waste streams and assessed the chemical profile of composts. We found elevated levels of non-physical contamination in some compost samples. We concluded that the only possible explanation for this is because chemically treated waste wood was in the feedstock material. Our current standard rules also allow tannery waste and paper pulp fibres – these wastes have not been sufficiently characterised. Because of the lack of data we cannot support continued inclusion of these waste streams.

We will remove the following waste types and descriptions from all standard rules permits:

• all 99 codes with the exception of plant residues and mushroom compost from the cultivation of mushrooms
• 99 coded waste has been replaced where appropriate with the correct waste codes
• waste wood as 03 02, 19 12 07, 20 01 38 and chapter 17 codes – all post-consumer and construction waste wood will be excluded – we have previously advised that waste wood from mixed sources such as from skip operators or civic amenity sites should not be composted as this type of waste wood is likely to have been chemically treated
• 07 chapter codes are removed due to the risk of chemicals being present

Correct coding requirements are set out in Waste classification technical guidance (WM3). The chapters describing the waste cannot be altered. For example chapter 17 construction and demolition waste cannot be substituted by chapter 19. Some chemical wood treatment, designed to prolong the life of the wood cannot be identified visually and requires regular sampling and testing for waste acceptance. Most chemically treated wood does not attract a hazardous waste code but most have hazardous properties such as biocides. The complexity of sampling and testing does not fit within the scope of a standard rules permit.

We have a clear goal of making sure the output from biological waste treatment and recovery is fit for (and highly desired by) the agricultural sector. The biowaste sector should not be used for the processing or diluting of difficult waste streams.

13. Plastic limits

Plastic contamination has reduced market confidence in using compost and digestate for agriculture. Even if compliant with BSI PAS 100 or 110 standards.

We proposed a 0.5% w/w (weight per weight) contamination limit on non-biodegradable plastic in the incoming waste. We would only allow plastic that is certified to EN 13432 standard.

We received 25 responses:

• agreed – 6
• disagreed – 16
• neither agreed nor disagreed – 3

Summary of responses

We received a great deal of support for restricting plastic contamination in waste feedstock material, showing recognition that plastic contamination is of serious concern.

It was recognised that current PAS 100 and PAS 110 standards allow some plastic leakage. And that some plastic fractions are:

• not compostable
• do not produce biogas

As food collection increases there is a benefit in addressing the issues now.

We received comments on the challenges faced by operators running facilities that accept both commercial and domestic food waste. These included:

• the pressures faced when competing for contracts and therefore having little choice in accepting heavily contaminated waste
• how the cost involved in ‘cleaning up’ feedstock would have a knock-on effect on the value of outputs – the current value of compost and digestate can be near zero, or even negative, in part due to their perceived low quality
• technical issues to sifting plastic upfront
• requirement to batch control being too prescriptive
• the difficulties in distinguishing between compostable packaging materials and non-compostable
• the amount of plastic entering plants can potentially cause technical issues to the plant
• the restriction does not capture microplastics
• the suggestion to transition the requirement over time, for example 1.5% w/w from 2021 and 0.5% w/w from 2023 and that these limits should apply to packaged food waste before treatment

We received comments about restricting plastic contamination to 0.5% w/w, some were from local authorities collecting food waste, including:

• the difficulties in getting householders to comply with use of compostable bags because of cost to them or the local authority to provide them
• communication issues with householders which could have more weight if backed up by central government
• a general reluctance on handling ‘naked’ food waste
• that if restrictions were put in it would lead to reduction in food waste collection and therefore resulting in impacting the waste strategy and the risk of more waste going to landfill or requiring thermal treatment
• having a negative impact on the desire to recycle food waste which will drive residual waste tonnages and costs up, thus harming the environment and not capturing biowaste for recycling and clean energy generation – ultimately pushing organic waste back down the waste hierarchy
• decreasing collection rate and increasing rejection

Our response

Tackling plastic waste in feedstock generated the most discussion of all our proposals.

We need to tackle it because:

• we need to address the potential risk of harm to people and the environment
• of the need to increase the value of the end material
• landowners have a lack of confidence in the quality of output
• agriculture holding tenancies and contracts have been lost where contaminated BSI PAS 100 and PAS 110 standard material has been used
• current household waste feedstock contracts are operating at a contamination rate of about 5% w/w
• we have estimated that around 600 tonnes of plastic fragments are spread to soils through digestate alone annually (based on PAS 110 allowing 0.125% contamination and 550,000 tonnes of food waste being treated by AD plants in England each year)

PAS 100 requires operators to reduce packaging before treatment. Therefore our proposals are not new. However, it allows the final material to contain the equivalent of 150 plastic bags for each tonne. We do not find this acceptable – this must change.

Imposing a tighter restriction on food waste treatment plants would impact 8 sites in England. The rest of the sites operate under bespoke permits.

After lengthy discussion with Defra, trade bodies and local authority representatives we have agreed the most pragmatic way forward to reduce plastic contamination is to take a staged approach. We have agreed, in principle, to aim for all non-compostable material being removed from household food waste collections by 2025.

This will be achieved by combining approaches.

Over the next 5 years we will:

• require all facilities to implement pre-acceptance and acceptance procedures that demonstrate waste contamination levels are minimised
• aim for a year on year reduction on incidental plastic contamination on waste received from kerbside collection, starting with non-compostable plastic at 5% w/w input for standard rules permits – but we will require operators to remove all non-compostable and digestate plastic contamination to as low as reasonably practicable prior to treatment

Where an operator wishes to continue to take highly contaminated waste streams they will need a bespoke permit. But they must demonstrate that plastic is removed to as low as reasonably practicable prior to processing. The majority of our food waste plants are already operating under bespoke permits and we will require them to demonstrate they have implemented this requirement.

By 2022 all operators taking contaminated feedstock will be required to demonstrate adequate and efficient plastic removal prior to and during processing. This includes under bespoke and standard rules permits.

All farm operations and green waste only sites should be able to control incidental plastic to a 0.5% w/w limit with immediate effect. They should work with local authorities and reject any contaminated loads as appropriate.

We will continue to use PAS criteria for meeting end of waste with the exception of plastic in the end material. For plastic we will require a year on year reduction above the current PAS 100 and PAS 110 limits. This will be similar to the approach the Scottish Environment Protection Agency has taken. These end material limits will apply irrespective of whether it is a certified ‘product’ or spread to land under a mobile plant deployment.

All output material will be recorded on waste returns.

We are also working with a range of stakeholders and government as part of a wider project to reduce single use non-compostable plastic.

In response to the comment regarding the requirement for batch control being too prescriptive, PAS 110 states under 7.1.5 that “each batch or portion of production shall be assigned a unique code, for quality management purposes”. For installations this is also a requirement under BREF and BAT conclusions.

14. Biosecurity

We intend to enhance biosecurity measures and reduce the risk of spreading invasive species.

Invasive alien species are becoming more resistant to herbicides and pesticides. We have limited plants like Japanese Knotweed spreading by excluding them from permits.

We intend to exclude manures, slurries and spoiled bedding and straw from farms where animals have notifiable diseases as stipulated in the Animal By-Products (Enforcement) (England) Regulations 2011 from standard rules permits.

We did not receive any comments about this proposal.

15. Amended descriptions

We intend to restrict some of the waste descriptions in the standard rules permits and remove the 99 codes (with the exception of plant waste from the cultivation of mushroom and spent mushroom compost):

• 03 03 10 fibre rejects are to be from virgin timber only
• chapter 15 codes packaging waste production must meet the EN 13432 standard or be certified as biodegradable
• 16 10 02 waste will only be allowed from facilities with waste codes listed in that specific rules set – for example a composting site can only receive leachate or liquors that have come from a site taking the same waste code
• 19 02 06 sludges from physico-chemical treatment other than those mentioned in 19 02 05 – if derived solely from physical treatment or pH adjustment of waste input types (or both) listed within the standard rules
• 19 08 05 sludge from treatment of urban waste water (sites that accept waste input types listed in the standard rules only as above)
• 19 12 01 paper and cardboard (excluding veneers, plastic coatings or laminates) meeting EN 13432 or equivalent certified standard
• 20 01 01 paper and cardboard (excluding veneers, plastic coatings or laminates) meeting EN 13432 or equivalent certified standard
• 20 01 39 plastic and packaging waste meeting EN 13432 standard or equivalent standard

We received no comments about this proposal.

Our response

We have been working with colleagues around issues specific to waste coding. With only one exception, we will remove 99 codes from all permits. We have used the waste guidance set out in WM3 and corrected waste streams miscoded as 99 codes.

The only exception is waste from the production of mushrooms – spent mushroom compost.

16. Sewage sludge code

The code for sewage sludge currently used in our standard rules is 19 08 05 from urban waste water treatment.

This can only apply to raw untreated sewage sludge. We proposed amending the 19 08 05 code and replacing it with the following codes:

• 19 02 06 sludge from physical chemical treatment other than mentioned in 19 02 05 (sewage sludge which has been previously pasteurised and stabilised only)
• 19 05 03 off-specification compost (previously composted sewage sludge only)
• 19 06 06 digestate from anaerobic treatment of animal and vegetable waste (previously digestate sewage sludge only)

This would make sure that operators can only receive treated sewage sludge under the standard rules permits.

SR2008 No 19 is the exception because it is intended solely for the digestion of sludge including raw sewage sludge.

We received 9 comments:

• agreed – 0
• disagreed – 9
• neither agreed nor disagreed – 0

Summary of responses

Water companies responded that altering waste codes may create a discrepancy in sludge data reporting. Current reporting guidance may have to be updated to align with the Environment Agency’s proposals.

The industry also felt that the change of hazard classification by introducing alternative waste codes to describe treated sewage sludge is problematic. Currently, treated sludge is coded as 19 09 08 and classified as ‘absolute non-hazardous’. The proposals will mean that treated sludge may be classified as ‘mirror hazardous’, to determine if the material is hazardous or not. The full impact of these additional sampling needs on operational practices are not yet clear. However, it is anticipated that this need for additional sampling and analysis will cause delays in sludge transport and spreading activities, leading to greater storage requirements at sludge treatment centres.

The industry went on to state that as an unintended consequence of the amended sewage sludge code, sewage sludge treatment centres could be classified as treating hazardous material. This would result in a mirror hazardous (MH) classification of treated sludge treatment operations for either disposal or recovery and with a capacity exceeding 10 tonnes per day would be subject to IED requirements, under Section 5.3 of the Environmental Permitting Regulations 2016.

The exclusion of persistent organic pollutants (POPs) contaminated sludge also makes the standard rules set unusable. If this clause is carried over into bespoke permits, the only form of sludge treatment available to water and sewage companies would be incineration with all the environmental disbenefit that would cause.

One water company felt that coding digested sludge as ‘19 06 06 digestate from anaerobic treatment of animal and vegetable waste’ is incorrect. Animal waste is defined in permit condition ‘4.4 Interpretation’ as not including faecal matter from animals. Sewage sludge is neither animal nor vegetable waste, and therefore this proposed code is not applicable. The industry stated that the Environment Agency must give clarity on what codes will replace 99 codes.

Other operators stated that they could no longer take advantage of standard rules permits as under the proposals and alterations to SR 2008 No 19 this only allows physical chemical treatment under a directly associated activity for treatment of waste codes 20 03 99 (cess pit waste), 20 03 06 (waste from sewage cleaning) and 19 08 09 (grease trap waste, fats oils and greases) as well as 20 03 04 septic tank waste.

Our response

We have applied the waste classification guidance as set out in WM3 and the waste streams are now correctly coded. Alternatives suggested by respondents do not follow the coding methodology in WM3.

The water industry receives many waste streams and treats them with urban waste water. It is important that operators assess the resulting sludge and classify it correctly using WM3. Additional representative sampling and analysis resulting from the need to characterise mirror code wastes can be carried out periodically, or by exception where there is reason to believe that the sludge may be atypical.

To operate under composting and AD permits, any waste sludge needs to be from treated urban waste water sludge only.

Any potential discrepancies in reporting sludge quantities to Europe will be managed.

The digestion of raw sewage sludge is allowed under the revised SR2008 No 19.

We have considered the impact of excluding sludges which containing POPs. Because of the non-source segregated nature of the urban waste water from which the sludge is produced and the practice of discharging industrial effluents to the head of waste water treatment works it is inevitable that all sewage sludge will contain POPs. We will therefore remove this restriction from the standard rules. We do however expect water companies to take measures to minimise the amount of POPs in the sludge.

We will provide further guidance on the corrected codes that replace the 99 codes previously used. This guidance will apply across the whole waste sector and include the exemption regime.

17. Additional waste types for composting operations

We propose the following additional waste types for open windrow composting (excluding smaller sites of less than 500 tonnes) and in-vessel composting.

19 05 01 non-composted fraction of municipal and similar wastes – from composting processes that accept waste input types listed in the standard rules and made up of previously sanitised batches only.

19 06 04 digestate from anaerobic treatment of municipal waste, separated fibre from a process that accepts waste input types listed in the standard rules or AD standard rules only.

We propose the following additional waste types for in-vessel closed systems.

19 05 01 non-composted fraction of municipal and similar wastes from composting processes that accept waste input types listed in these standard rules and made up of previously sanitised batches only.

19 05 02 non-composted fraction of animal and vegetable waste from composting processes that accept waste input types listed in these standard rules, made up of previously sanitised batches only.

19 06 03 liquor from anaerobic treatment of municipal waste (from a process that accepts waste input types listed in these standard rules or AD standard rules only).

19 06 04 digestate from anaerobic treatment of municipal waste separated fibre from a process that accepts waste input types listed in these standard rules or AD standard rules only.

19 06 05 liquor from anaerobic treatment of animal and vegetable waste from a process that accepts waste input types listed in these standard rules or AD.

19 06 06 digestate from anaerobic treatment of animal and vegetable waste, separated fibre from a process that accepts waste input types listed in these standard rules or AD standard rules only.

The additional waste codes will allow the recovery of digestate fibre. This is in recognition of compostable packaging requiring further treatment. This will improve the digestate market. Composting fibre will also reduce ammonia emissions during storage.

We received no responses about this.

Our response

We will add the additional waste codes and types as set out in our consultation.

We will also add untreated sheep fleece ‘off specification product’ to open windrow and small scale composting sites, where for example there is not a market for the fleece.

18. Commissioning facilities and Hazard operability study

All new facilities should have a commissioning plan in place before they receive any waste. Existing sites should submit a recommissioning plan before restarting after a period of shut down or refurbishment. This is not needed for routine planned maintenance.

We proposed that all facilities carry out a Hazard operability study (HAZOP) or similar risk assessment and act on the findings for critical work and maintenance. Operators should already have a detailed programme of works in their EMS procedures. We think this is an appropriate measure and best practice.

We received 5 comments:

• agreed – 3
• disagreed – 1
• neither agreed nor disagreed – 1

Summary of responses

One operator and one trade body stated that HAZOP studies are costly and that operators should have an understanding of the site and the process rather than adhering to a plan that may or may not be adequate. They added that they did not feel that the Environment Agency had the competence or understanding of the commissioning process and may not be able to respond in a timely manner.

Other respondents agreed with the proposal and welcomed this intervention. They thought if a competent person did a HAZOP study at every site there would be no need for prescriptive conditions.

One water company responded that although they agreed they did not currently have a process and instrumentation diagram to a concise standard for all sites. This would add substantial cost.

One trade body asked that we amend the term ‘decommissioning’ to ‘periods of dormancy’ but supported the rationale to recommission after periods of dormancy.

Our response

We do not propose nor intend to approve commissioning plans. We do however, require that the operator has a plan drafted by a competent person before operating or restarting. The purpose of a commissioning plan is to identify and mitigate risks during one of the highest risk stages in operating a site.

A formal HAZOP or similar risk assessment that demonstrates and periodically reviews risk and risk mitigation is a standard requirement in most other industry sectors and can be done at any time during the operational life of a site.

Irrespective of operator experience a well-constructed HAZOP plan that is reviewed and revised, will identify any issues and measures that need to be taken as they arise on a day to day operational basis.

We will set out a condition in our standard rules permits which implements this proposal.

19. Reducing emissions

Many polluting emissions relate to feedstock controls, storage, ineffective processing and, or ineffective abatement systems (or both). We propose to improve the control of emissions and prevention of pollution in the operational techniques.

This relates not only to odour but specifically ammonia and other pollutants. For example most of the current estimates of atmospheric ammonia are based on the assumption that all lagoons and stores are covered and that there is 95% abatement for ammonia. In practice this is not the case.

We received 12 responses.

• agreed – 2
• disagreed – 4
• neither agreed or disagreed – 6

As the proposed measures were across the revised permits we will respond to specific comments.

19.1 Odour – general comments

Summary of response

One respondent stated that the Environment Agency needs to consider the context of the odour complaints received and any substantiating evidence that may support of the need for odour.

One operator stated that they accept slurry and do not consider this to be waste. They felt that applying waste controls is inappropriate for this activity.

One water company stated that the additional requirements for monitoring and annual reporting of odour abatement, covering all storage lagoons and tanks, putting in leakage detection, and having storage contingencies in place (when the landbank is unavailable) will add a burden to the operator and is disproportionate and unreasonable.

Another water treatment operator queried if the requirement to store quarantined and rejected waste in closed containers or covered and removed to a regulated facility within 5 days applied to final biosolids that have failed Hazard Analysis Critical Control Point Procedures. They added that the requirement for all tanker loading and discharge points to be within buildings, would be excessively expensive.

One company stated that operators should be given the choice of monitoring odour or ammonia and H₂S, but not both.

One trade body expressed that these were positive steps as the AD sector has been allowed to operate to lower standards than other regulated sectors. They felt the proposals at last achieve a level regulatory playing field across industry sectors.

Our response

We are aware of situations where local relationships are sometimes difficult between operators and local communities and are well conversant with these dynamics. However, as a regulator we are required to ensure all appropriate measures have been used and that we follow up complaints as required.

Standard rules permits require minimal assessment on application. The issues often arise when operators are asked to produce additional information in the event of a complaint or non-compliance. The standard rules permits set out the minimum standards that operators must follow - this allows us to issue a permit with the correct level of assessment for this type of permit.

In response to the comments on the waste status of slurry and manures. Slurry and manures are waste. In 2009, to support the farming sector we developed a position which allowed storage and handling of digested slurry and manure without waste controls when the digestate was spread to land. We are reviewing this position in the near future.

Monitoring and reporting odour, covering tanks to abate emissions, and leakage detection are all good practice and in many cases required as BAT.

The requirement for contingency planning to manage sludge in periods when the landbank is unavailable is not new. It is also an essential part of risk management to avoid non-compliance. We already expect this to be a standard feature of water company bioresources planning.

The proposal for tanker discharging to be housed within a building will be removed from SR2008 No 19. Instead operators will be expected to address odour risk within the odour management plan.

19.2 Feedstock controls

We proposed the following:

• to include in the operational techniques section of our standard rules permit conditions to control feedstock and waste storage
• a requirement to monitor waste feedstock on compost sites to ensure that biodegradation is managed
• covering storage of high ammonia feedstock such as chicken manure
• bulking and transferring waste to be carried out in an enclosed building
• linking all tank transfers to an abatement system

We received 4 responses:

• agreed – 1
• disagreed – 1
• neither agreed nor disagreed – 2

Summary of responses

One respondent stated that the Environment Agency needs to be more descriptive and expand what they consider to be high ammonia feedstock and to publish a list of these. They thought covering high ammonia feedstocks like manure and poultry litter may act as a disincentive and that instead the location to sensitive receptors should be considered.

One respondent wanted to know if this proposal applied to digestate.

Another commented that the proposed requirements of waste storage to be within a building, the need for air extraction for tanks and lagoons, abatement for digestate drying and tanker loading in a building were too onerous. They felt these operations were better addressed through an emission monitoring plan and an odour management plan.

One commented that most on-farm anaerobic digesters are on the same site as where the manure waste is produced. Therefore most transfers occur by gravity feed or pumped pipe work. This operation would not cause an emissions issue.

Other comments received stated that supervising transfers was not feasible on small sites.

One operator stated that changing pipework and process flows into a bund is technically difficult and expensive.

Our response

The objective for covering stored waste feedstock is to prevent all emissions, not just odour. The complexity of the cover should be tailored to the operation to mitigate emissions. The appropriate measures for covers will be set out in our new appropriate measures guidance. Sites receiving food waste must already do so in an enclosed building with air extraction and abatement. This is not a new requirement for those sites.

We will include the requirement to use appropriate measures for limiting emissions and odour from bulk tanker transfer for slurry and manure.

We do not consider that providing a list of high nitrogen feedstocks is necessary. Operators should understand their feedstock, be in control of processing it and be able to justify their decision to us.

If operators do not want to cover their storage facilities and can demonstrate that there is no impact on sensitive receptors, to issue a permit we would need to validate this by carrying out a site specific risk assessment. Our standard rules permits set allowable distances between sites and sensitive receptors. We could consider extending the set back distances but this would only deal with localised emissions and not wider impacts.

We have reconsidered the proposed requirement to store manure and slurry in an enclosed building. We will amend the wording to allow covered storage. Our existing permits already have rules to control fugitive and odour emissions. Assessing and approving odour management plans can be costly and lengthy. We feel that setting out the required measures in both our standard rules permits and our appropriate measures guidance will provide a clear indication of the type of cover we expect.

We consider that supervising tanker transfers should already be part of the waste acceptance and discharge processes irrespective of the size of the operation. We know that pollution resulting from unsupervised discharges have caused significant harm to the environment.

We do not accept that transferring digestate outside of a bunded area represents best practice and is of low risk. We know that significant pollution events have been caused when pipe work has penetrated the bund walls or where systems outside a bunded area have failed. We will set out in our standard rules permits that transfers made outside of a bunded area must be supervised at all times.

19.3 Demonstrating abatement efficiency

Facilities that depend on abatement should have to demonstrate that the plant is designed and built to manage emissions and is maintained to make sure it remains fit for purpose. We therefore propose to include in our standard rules permit a requirement to monitor abatement efficiency and report it to us annually. For waste installations standard rules permits we are required to prescribe emission limit values.

We received 5 responses:

• agreed – 1
• disagreed – 2
• neither agreed nor disagreed – 2

Summary of responses

One respondent acknowledged that the sector does cause odour but not all wastes are equal in respects to odour potential.

Others stated that they did not support yearly efficiency reporting due to the expense involved. Using a proxy chemical such as H₂S, then a threshold limit could be adopted instead.

Another stated that the cost for monitoring all stacks, including inlet odour control units by olfactometry at 25 sewage treatment works would be approximately £230k per annum (£115k every 6 months). Therefore, it would be appropriate to use H₂S as surrogate.

Our response

We expect that all abatement systems are designed, built, maintained and tested to ensure they remain fit for purpose. Existing standard rules require this. As in other areas of process regulation, monitoring is required to ensure that the abatement system is effective and remains fit for purpose. For installations the waste treatment BREF and BAT conclusions require that for a continuous discharge, daily averages can be used. The frequency for installations is once every 6 months as set out in the BREF.

The use of H₂S as a proxy is not well established in terms of odour or ammonia and therefore is not a direct substitute. BAT AELs state that both ammonia and H₂S together can be used as alternatives to odour monitoring.

We will implement the requirement to monitor and report at a frequency in line with BAT conclusions.

However, for smaller scale operations (for example, waste) we will require efficiency monitoring in accordance with the frequency stated in an agreed odour management plan. For sites that are drying digestate and abating ammonia, the monitoring frequency will remain annual as the rate of ammonia loss can be substantial.

19.4 Incidents and failures

We proposed the following:

• a requirement to review and investigate all failures and incidents
• that the EMS must include a schedule of planned work and critical infrastructure assessment
• a requirement to install lightening conduction
• a requirement to install foaming and foam sensing

We received 3 responses:

• agreed – 0
• disagreed – 1
• neither agreed or disagreed – 2

Summary of responses

One operator stated that the Environment Agency should emphasise the need for operational staff to do daily visual checks.

One operator stated that a good HAZOP or other risk assessment will identify the most appropriate techniques for lightening conduction and should provide a mitigation technique.

Another operator stated that there was no need to install foam control sensors or use anti-foaming agents in digesters. Current site level sensors and pressure sensors should be adequate and process monitoring should be the first stage in detecting this.

Our response

Under condition 1.1 of our standard rules permit there is already a requirement to develop an adequate EMS. We do not consider that this requirement gives enough visibility to managing incidents and failures as operators have not generally implemented these safeguards.

We will require operators to carry out monitoring to ensure stable conditions during digestion treatment and to use level sensors to prevent over-topping. We will provide the monitoring requirements in our appropriate measures technical guidance. This will include the requirement to re-calibrate pressure and vacuum relief systems after an over-topping event.

We will cover the use of lightening conduction in our appropriate measures technical guidance.

19.5 Covering tanks and lagoons to prevent emissions to air

We proposed that:

• all storage lagoons and tanks (such as digestate and dirty water) should be covered and that air should be extracted and abated
• all lagoons and tanks to have a freeboard (or head space) of at least 750 mm

We received 8 responses:

• agreed – 3
• disagreed – 1
• neither agreed nor disagreed – 4

Summary of responses

Those that agreed with these proposals agreed that emissions need to be considered at every stage of the process.

One operator stated that tanks are not the same as lagoons and are filled to a higher capacity and therefore do not need a 750mm freeboard.

One respondent believes ammonia rich feedstock digestate should follow the same capacity standards as SSAFO regulations as they pose similar risks.

Concern was raised over covering lagoons and tanks, including carrying out abatement and air extraction – this is expensive and can pose health and safety issues for workers.

One respondent stated that lagoon covers in certain situations cost £75 per cubic metre although they did not state the type of cover this referred to.

One operator stated that the Environment Agency should accept that there is a difference between high nitrogen and low nitrogen materials.

One water company stated that the cost of ensuring secure storage of digestate, including whole or liquid fractions in covered tanks implies that all secondary digesters need to be covered and that this will incur excessive cost.

One water company stated that the increases in emissions from biowaste treatment must be strongly attributed to the rapid increase in the numbers of facilities developed in the time period 2010 to 2017. It would therefore be sensible for emission management to form part of the planning considerations of new plants and the proximity of new constructions to existing ones.

Other comments stated that biosolids and cake storage pads are not covered, although previous bioaerosol monitoring has shown these not to be a risk.

Our response

The government’s Clean Air Strategy prioritises reducing ammonia emissions. We will help implement this strategy by putting measures in place to reduce ammonia emissions from biowaste sites. By 2023 we expect all lagoons and open-top tanks will be required to be covered. This requirement is set out in the government’s Clean Air Strategy.

Our current standard rules permit already requires that storage of digestate from the AD of food waste is enclosed to minimise release of emissions, including ammonia. We will ensure that all digestate and leachate liquors in storage are covered. In our guidance we will set out the type of covers that are appropriate to minimise releases at existing on-farm AD sites. We will expect all new facilities to cover lagoons with a fixed cover.

Covers are required to prevent or minimise emissions, including ammonia loss exacerbated from air turbulence across the surface of open lagoons. We have set out appropriate measures for covers in our new appropriate measures technical guidance. Lagoons for example should be covered using either effective or correctly applied floating covers or engineered fixed covers. We recognise that for existing facilities to add a fixed cover may be cost prohibitive and it may not be safe to do so. We suggested using a floating cover in our consultation. Suitable covers can include textile sheeting, synthetic membranes and organic materials such as straw and wood-chip. The choice of cover depends on the risk to receptors. Industry are already using a range of covers effectively.

Where fixed covers are used for digestate tank storage, gases should be removed from the head space. Where they cannot be used, for example in gas engines, they should be abated.

This applies to on-farm digesters. Existing standard rules permit conditions for food waste AD already require use of fixed covers. So this is not a change for food waste AD operations. We will allow time for on farm sites to apply floating covers to existing lagoon storage.

In response to comments about emission of bioaerosols, these particulates behave differently in dispersal. Therefore we do not consider comparing particulates and other gaseous emissions appropriate. We set restrictions on how close a site can be located to sensitive receptors to manage the risk of bioaerosol emissions and allows for adequate grounding.

The benefits of covering stores are threefold:

1. Solid covers prevent rain from filling the lagoon or tank, making storage capacity more predictable.

2. Covers will minimise emissions that impact the local and wider environment.

3. Covers minimise nitrogen loss from volatilising during storage and increase the nitrogen value of the final material as a fertiliser.

Tanks should only be filled to their design capacity limit. This can be set out in the EMS and we will amend the wording of the permit to reflect this.

With regard to acknowledging the different nitrogen levels in material, we think any potentially polluting material needs to be safely contained and managed. Storage containers must be correctly designed and constructed with adequate capacity to prevent overfilling and with covers to prevent emissions and inundation by rainwater.

19.6 Pressure relief valves, leak detection and flares

We proposed that auxiliary flares must be available on site and used immediately in the event of process failure or during maintenance. The operator must maintain a record of use and submit an annual report to the Environment Agency. The records must include date, time and duration of the event and an estimate of the mass release. We proposed that AD operators should implement leak detection devices on site to prevent emissions. We proposed that pressure relief valves should be of the correct design and size. The valves should be checked to ensure reseating after release.

We received 5 comments:

• agreed – 1
• disagreed – 2
• neither agreed nor disagreed – 2

Summary of responses

One respondent stated that they did not disagree that addressing emissions, especially methane and NOx is important and how they are monitored is very important. They agreed that pressure relief valves should be correctly sized, fitted and maintained but operators do not always know when the valve is activated.

There was also agreement that emissions of methane and ammonia need reducing and that the Environment Agency needs to stipulate what needs to be included in the Leak Detection and Repair (LDAR).

One operator stated that they cannot be expected to manually track pressure relief valve activity - they can be in use all day depending on design of the site.

One water company operator stated that they did not have a supervisory control and data acquisition (SCADA) system at all sites as some sites monitor flares and pressure relief valves locally via programmable logic controllers. There will be a significant cost to transfer this data back to a SCADA system. They added that the requirement to ‘review and record’ energy efficiency, raw materials and waste products ‘was already part of a 5 yearly price review process’. And the permit process states every four years.

One operator agreed that flares should be available but technically referred to as surplus gas burners (SGB) and that the SGB should be known as an auxiliary gas consumer. The wording of the permit draft implies that an additional flare is required. The condition is not necessary due to the fact the flare should be maintained and serviced in line with the maintenance schedule.

One operator stated that installing a flare would be costly.

Our response.

We want operators to prevent all emissions and where it is not possible to minimise them.

We think plants should already have digester tanks designed to accommodate operational gas pressure variations and that all plants should already record operation pressures on their SCADA system. We also expect that SCADA systems are able to record gas pressure which will indicate the likelihood and frequency that the pressure relief valves are activated.

We consider that routine checks, maintenance and validation test certificates should ensure that pressure relief valves are in good working order and operate to the designed pressure range.

We think the valves should already be correctly sized for the plant and installed, maintained and calibrated in line with industry standards.

Tanks should already be designed to withstand pressure variations and the need to engage pressure relief valves should be minimal. We have set this standard in our requirements for other industry sectors. We will set the validation and inspection requirements in our standard rules permits.

We think all sites should have a standby flare or the ability to burn gas during and an emergency or maintenance. Venting biogas direct to atmosphere is not allowed unless through a pressure relief valve to prevent catastrophic plant failure.

All flares must ensure that volatile and trace substances are destroyed in line with manufactures specifications.

We will implement the requirement to have foam sensors in digester tanks though our standard rules permit conditions.

19.7 Requirement for contingency storage

We proposed that all sites have storage contingency for periods when the landbank is unavailable.

We received 4 responses:

• agreed – 2
• disagreed – 1
• neither agreed nor disagreed – 1

Summary of responses

Some respondents agreed that all sites must have contingency for when landbank is unavailable and that includes extreme weather events. Also that off-farm AD sites should have robust contingency plans regarding adequate storage. Two months storage is not sufficient in all cases. Perhaps this needs to mirror other regulations like the slurry storage closed periods. Their preference is that any change is introduced as best practice in the first instance.

Another commented that having storage contingency in place adds a very heavy burden to the operator.

Our response

The landbank is routinely unavailable during closed spreading periods, flooding, cold weather and other extreme events. This is occurring more often and over the last few years we have dealt with this through a series of temporary regulatory position statements. Operators must plan for this situation. It is critical that all operators have an agile way of dealing with extreme weather events and that they prepare for the effects of climate change in the longer term.

We will include a new condition in our standard rules permits that require operators to have a contingency measure for storage of material either on or off site with a minimum storage time of two months. The contingency storage location must meet legal requirements.

Water company concerns about the need for contingency storage are surprising given that we have been emphasising the need for this since at least 2012. Contingency storage can be organised on a company wide basis and will not require each site to have fixed amounts of sludge storage. This will allow operators to deliver the necessary storage capacity flexibly and minimise the costs.

20. Fire prevention

We intend to add additional fire prevention measures. We propose the following measures:

• representative temperature monitoring throughout a compost windrow and in stock piles, for example over-size – this will be in line with our published fire prevention plan guidance
• temperature monitoring of maturing and oversize materials, for example, during the composting of digestate
• safe storage of activated carbon (new and used)

We received 1 response:

• agreed – 1
• disagreed – 0
• neither agreed nor disagreed – 0

Summary of response

The respondent welcomed the need for all sites to have a fire prevention plan including The Dangerous Substances and Explosive Atmospheres Regulations (DSEAR) and a lightening conduction assessment condition and stated that all operators should have these as standard in their EMS.

The purpose of a LDAR was agreed but the Environment Agency need to provide more information about how leak detection is done. The operator states that personal gas detection devices should be sufficient.

Our response

We will set out the requirement for a fire prevention condition in our standard rules permits which will include a DSEAR assessment. Our fire prevention plan guidance will explain what is needed.

We have included leak detection and repair monitoring as a permit requirement. This will:

• save operators money through lost gas
• minimise fugitive emissions (an existing permit condition)
• improve health and safety

A number of companies offer this assessment. Many sites have installed these systems. Therefore they are available to the sector and are understood. We will provide more detail in our appropriate measures guidance.

21. Water harvesting and separation of clean water and fouled water

We proposed that all facilities harvest and utilise clean surface water and where possible divert clean surface water from dirty water areas. This is a BAT requirement.

This would:

• reduce abstraction volumes and reliance on potable water supply and associated costs
• provide water for maintaining housekeeping and for firefighting
• ensure surface water does not contribute to the volume of leachate collected in lagoons, reducing cost of disposal

We consider these are existing appropriate measures.

We received 2 responses:

• agreed – 1
• disagreed – 0
• neither agreed nor disagreed – 1

Summary of responses

One respondent believes that water separation (clean and dirty) should not be mandatory and stated that it is best practice to collect, separate and reuse water captured. This should remain voluntary because the additional cost for retro-fitting exceeds the benefits.

Our response

We will not refer to any requirement for water harvesting in our standard rules other than to state it should be implemented where possible. We have experienced very warm dry periods over the last few years which can cause shortages of ‘on-site’ water supply. Water harvesting can reduce bills in the long term. We must all try to reduce water usage – drinking water is increasingly a resource under pressure. This is a requirement of BREF and BAT. We will cover this in more detail in our appropriate measures guidance.

22. Changes to operating techniques – monitoring and process control

All operators are required to demonstrate good process control. In our call for evidence we asked how good operational performance should be reflected in the permit conditions.

We know that non-compliance arises from poor or poorly implemented EMSs. Inadequate infrastructure design and poor maintenance are also contributing factors.

We have consulted on these measures with industry and insurance companies who are in support of the proposed amendments.

These measures should be incorporated in the operator’s EMS but we find often that they are not.

We received 3 comments:

• agreed – 0
• disagreed – 3
• neither agreed nor disagreed – 0

Summary of responses

Respondents felt that the additional operational techniques were too prescriptive, for example the lightening conduction risk assessment condition.

They thought guidance should be enough and be published when standard rules are available.

Others thought some process monitoring requirements within the proposals are unnecessary for low risk sites and onerous. One comment referred to the requirement for yearly de-gritting would be feedstock dependant and that the additional monitoring would not be understood by the Environment Agency.

They said de-gritting was either done continuously in concrete tanks or using a dip tape would be sufficient. One water company commented they were unsure of the benefit of lithium tracing as this technique did not give 100% accurate results and was expensive.

Our response

We believe the operational techniques should be included in the permit to improve standards and compliance. These conditions reflect baseline standards.

The build-up of grit causes significant issues at AD operations and loss of productivity and tank failure. We will set out our requirements in our guidance. We expect operators to have considered what measures are needed and include in their EMS a preventative maintenance programme procedure. We have amended a requirement for degritting and instead referred to this as a monitoring requirement dependant on the tank design and manufacturers specifications.

Additional appropriate measures guidance will be available by spring 2021.

23. Waste and material data returns

Operators are already required to submit waste data returns for waste entering and leaving the site. Our data demonstrates a gap in the tonnage reported as recovered for compost and digestate. We proposed that all material leaving the site, including certified material, is recorded.

Operators already submit waste returns to us on a quarterly basis so we do not expect this to introduce any additional cost.

We have included additional interpretations to ensure operators understand how to comply with their permit.

We received 1 response:

• agreed – 1

Summary of response

The respondent supported the requirement for all operators to record all materials leaving site including products.

Our response

This requires no change to our proposal. We will also amend reporting requirements in bespoke permits during the permit review.

24. Medium combustion plant and specified generators

We will require operators to notify us of any installed and modified combustion and generating units.

We received no comments.

25. Changes to individual permits

SR 2010 No 14 and SR 2011 No 1 – 500t small scale aerobic composting

These standard rules permits enable small scale operations at levels above the T23 waste exemption but below a full scale commercial composting operation. We expect these smaller scale operations will be composting waste produced nearby or at the place of production.

We will include a daily capacity limit of 75 tonnes in treatment to ensure operations are below the installation threshold.

We have removed the requirement for mixing feedstock ratios in SR 2011 No 1 and intend to allow a wider variety of waste feedstock.

We will incorporate SR 2011 No 1 into SR 2010 No 14 and then withdraw SR 2011 No 1.

We will deal with these as an administration variation and there will be no cost to permit holders. The consolidated rule set does not introduce new restrictions other than a daily limit. Operators who exceed this limit should have an installation permit already.

We received 1 response:

• agreed – 0
• disagreed – 0
• neither agreed nor disagreed – 1

Summary of response

The operator stated that it was difficult to ascertain what the intended changes will be, they are currently operating under SR2011 No 1.

Our response

We are consolidating these permits into one permit. Existing operators will have no change other than to daily capacity limits of 75 tonnes in line with IED and Environmental permitting regulations. Operators will be moved to one consolidated permit at no cost.

SR2008 No 16 – 25kte and 75kte: composting in open systems

We intend to include a daily capacity limit of 75 tonnes to ensure operations are below the installation threshold. We will move SR2008 No 16 25kte and 75kte permit holders to the latest rule set SR2012 No 7. Earlier versions will be withdrawn.

We will deal with these as an administration variation and there will be no cost to permit holders. Operators that exceed the 75 tonnes per day in treatment or the annual tonnage of 35 000 should have an installation permit already.

We received no comments.

SR2012 No 7 v2.0 – composting in open systems

In 2012 we restricted the total amount of waste that can be accepted to 75 tonnes in any one day to remove the risk of stockpiling. However, this restriction has little effect on preventing odour and may restrict operators contractually. We consider that actively managing pre-acceptance and acceptance of waste feedstocks will prevent anaerobic conditions and is more fundamental to controlling emissions, for example odour.

Waste returns data indicate that these sites operate below 30,000 tonnes of waste per year. We propose that yearly tonnages are reduced from 75,000 tonnes per year to 35,000 tonnes per year. However, operations must not exceed the design capacity of the site.

We have increased the amount of waste that can be accepted to 100 tonnes per day, providing the waste waiting for treatment is stored and monitored to prevent anaerobic conditions. In addition we will allow operators to store up to 200 tonnes of waste for up to 5 days prior to processing.

There will be no effect on costs. Waste returns data show that operators using SR2012 No 7 process less than 30,000 tonnes of waste per annum. Operators should already have an installation permit if they treat or have capacity to treat over 75 tonnes of waste per day.

We received no comments.

SR2008 No 17 and SR2012 No 3 – composting in closed systems

We propose that the older versions of standard rules permits, SR2008 No 17 and 2012 No 3 will be moved to one consolidated version.

We will deal with these as an administrative variation and there will be no cost to permit holders.

We received 2 responses with no further details or comments.

SR 2008 No 19 – anaerobic digestion of sewage sludge

A number of responses suggested that greater reliance should be placed on the EMS instead of requiring operators to comply with a detailed list of operating techniques. We do not agree. The standard rules must require operators to comply with all relevant aspects of BAT and this is not guaranteed simply by relying on an EMS.

Condition 4.2.3 on recording of non-waste materials leaving the site has been removed as this would be relevant mainly to end of waste materials.

26. Other comments

We were asked for clarification on whether 10 tonnes per day of animal waste only relates to animal by-product feedstocks for AD plants, and not poultry litter and manure.

One respondent noted that table 2.1 A3 states that ‘The medium combustion plant or generator (or both) must not have secondary abatement or be mobile’. We are unsure as to how this will apply for dual fuel units and mobile plants, particularly where there is a temporary need for a ‘swing engine’ that is required to support longer periods of maintenance outage of the usual combined heat and power engines.

Our response

The 10 tonnes per day limit of animal waste is specifically for category 3 animal by-product waste.

Over 10 tonnes per day means the activity is an installation activity for biowaste. For advice on categorising animal waste, including manure and slurry please refer to Animal and Plant Health Agency (APHA) guidance.

We have amended the standard rules permit to say that where secondary abatement is required for NOx emission limit value compliance, monitoring shall begin:

• 10 minutes from when a generator starts operating
• 20 minutes for a generator that was a Tranche A and is now a Tranche B

27. List of respondents

Here are the respondents (who agreed their response could be published):

• Ixora Energy Ltd
• AmeyCespa Ltd
• SUEZ Recycling and Recovery UK Ltd
• Natural England - Catchment Sensitive Farming Team and Air Quality Network
• C Clarkson and Son
• Shann Pitts Consulting
• Anglian Water Services Limited
• LARAC (The Local Authority Recycling Advisory Committee)
• Andigestion Ltd
• Enva Resource Management
• Severn Trent Green Power
• Bio-based and Biodegradable Industries Association (BBIA)
• Assured Energy LLP
• Environmental Services Association
• 4R Group
• ADBA (Anaerobic Digestion & Bioresources Association)
• Association of Directors of Environment, Economy, Planning & Transport (ADEPT)
• Marches Biogas Ltd
• United Utilities
• Langage AD LLP
• CIWM (Chartered Institution of Wastes Management)
• Devon County Council
• Oxfordshire Resources and Waste Partnership (Oxfordshire County Council, Cherwell District Council)
• The Hertfordshire Waste Partnership, (HWP)
• FABRA UK (Foodchain and Biomass Renewables Association)
• Thames Water
• Severn Trent Water
• Northumbrian Water
• Yorkshire Water
• Gloucestershire County Council
• North London Waste Authority
• Stevenage Borough Council
• Wildmore Renewables Ltd
• Grange Farm Renewable Energy Ltd
• Manor Farm Community Energy Ltd
• Clapgate Farm Energy Ltd
• REA (The Association for Renewable Energy & Clean Technology)
• REAL (Renewable Energy Assurance Ltd)
• NFU (National Farmers Union)