NFU letter to EA highlighting concerns
Following recent developments affecting the on-farm composting sector - i.e. the transition from waste exemptions to permits and recent consultation on changes to standard permits - the NFU has written to the Environment Agency outlining our concerns for the on-farm waste treatment sector.
We covered the following points in our letter:
- High permitting costs and inflexibility within the standard rules is a huge concern for smaller composting operations moving from exemptions to permitting.
- That farmhouses and other buildings located on-farm are considered by the EA as meeting the definition of “sensitive receptor” and this pushes many operators into expensive Bespoke Permits, rendering the operation uneconomic.
- “End-of-waste” status for compost and digestate is unfortunately not a realistic option for most farm-based operations due to high costs in the certification process, therefore the burden of regulatory cost must be minimised to ensure on-farm composting remains economically viable.
- The regulatory burden could be lessened by consolidating Standard Permits to include both the waste treatment operation (i.e. composting or anaerobic digestion) and spreading the resulting material onto agricultural land where these occur on the same site.
- We also felt that the 50 hectare limit for deployments under the Standard Permit for landspreading limited on-farm operations.
- We reiterated feedback from members who have found that the Environmental Permitting process can easily turn what could have been a beneficial operation into a costly, time consuming exercise and our frustration with the lack of transparency in fee structure.
We are currently awaiting formal response. Any further concerns or feedback from members can be sent to nicola.dunn@nfu.org.uk or posted in the comments box below.
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