Obtaining and Operating within Environment Agency

Permits for on-farm Anaerobic Digestion

When planning a digester it is essential to be aware of both the impact and cost of

permitting on the total project. Feed in Tariff payments are also made on the condition

that all legislation is complied with. The regulations classify the storage and treatment of

waste, the burning of biogas and the application of digestate to land as waste activities

and are therefore controlled under the Environmental Permitting (England and Wales)

Regulations 2010.

Evidence to obtain and maintain the necessary permit is now procedural and fact-

based, producing Environmental Management Systems and management plans all of

which are living documents and checked by more frequent Environment Agency visits.

Charges vary according to classification but are based on risk scoring - the higher the

risk, the more you pay. This is a major step away from the less-regulated agricultural

industry that we know and the realisation that the legislation is the same as that set up

to control scrap yards and recycling centres.

E and J Solutions now incorporate permitting into the feasibility, design, and planning

stages of the process. At the design stage it can be moved and costs and long term

permitting workload reduced.

Statutory Compliance

E & J Solutions Ltd

Craven Grain Storage

The Airfield

Shobdon

Leominster

Herefordshire

HR6 9NR

01568 708925

enquiries@eandjsolutions.co.uk

There are several options to ensure compliance on the farm.

Exemption

A free exemption can be obtained if the operation is based on the low risk of handling

less than 1250 cubic metres of in-process material with a net rated thermal input of up

to 0.4 MW, and for a retention time of at least 28 days.

Standard Rules Permit

Medium to high risk activities require a standard permit as the risks and conditions have

been assessed by the Environment Agency. This “Anaerobic digestion of waste for the

purpose of recovery” permit allows the storage and treatment of over 1250 tonnes of

feedstock, covering manures, slurries and crop material. This permit also covers the

burning of biogas. The site cannot be located within the proximity of certain

environmental features such as SSSI’s (Site of Special Scientific Interest),

watercourses, boreholes, Groundwater Protection Zones, etc.

Bespoke Permit

If the site falls outside the above criteria (including the use of other waster materials),

the assumed EA risk rises to high and a bespoke permit is required. There is also a

need to prove that any potential environmental impact is being reduced.

Variation Permit

For others, including those with poultry units, it may be possible to vary an existing

permit to include the digestion activity but it depends on the scale of the operation as a

significant variation will always be required to have its own dedicated permit.

Thinking about the development of the plant over the coming 5 years will ensure that

sufficient scope is built in to allow it to develop in the interim. Never underestimate the

workload that will be required to obtain and operate a permit for an AD site.

It is vital to remember that without pasteurisation and PAS 110 compliance none of the

above permits cover the permitting and application of digestate to land where waste has

been used as a feedstock. This must be carried out as a separate procedure.

Good advice implemented early on in the project will save significant amounts of time

and effort and the most profitable projects are those that minimise delays during the

project development, construction and commissioning phases.