The Environment Agency (EA) has announced that the Compost, Anaerobic Digestate (AD) and Poultry Litter Ash Quality Protocols (QPs) need to be revised to enable the EA to continue supporting them (ie. for the end-of-waste positions to remain). The NFU is keen to work together with industry partners and the EA to take these revisions forward to ensure we retain end-of-waste options for waste-derived composts and digestates.
The revisions will affect producers in England, and potentially Wales, and are an opportunity for stakeholders to work together to improve these QPs.
The EA has stated that these revisions will need to be paid for by industry. In response to the announcement, industry partners have called for this to be co-funded by the government, with industry inputting its time and resources into the process. However, Defra has insisted that these revisions will need to be industry funded.
If funding is not provided by industry, the EA will not set up a Task and Finish Group to progress the review and will withdraw support for these QPs. This would mean that all composts, digestates and poultry litter ash would be classified as waste and need to be used under waste regulatory controls (deployments). This route has a significant cost impact for most producers and end users.
Funding is needed
Industry associations have therefore agreed to collaborate on raising sufficient funds from industry to pay for these revisions. The EA’s estimated minimum cost is £25,000 per QP, for addressing the topics they have said need attention, but this could increase depending on what changes industry would like to be considered, and if further evidence gathering or external technical expertise is needed.
The EA has stated that the more information the industry is able to provide, the less the total cost of the revision; this is because the EA’s charges will not include costs of providing extra evidence required or additional consultancy fees for obtaining, collating and providing such evidence.
We will endeavour to protect our members’ interests and closely monitor any significant increase in the costs suggested by the EA in relation to these workstreams.
Call for contributions
The compost and digestate industry representatives are inviting contributions for this important work. The overall cost burden is shared if all those involved in the process of producing end-of-waste material donate a minimum of £500 per process/site they operate, including any process that produces digestate only from manures or slurries, or co-digests them with energy crops.
Sites processing larger volumes may wish to contribute more. Contributions from organisations who are not producers-of-end of waste materials covered by these QPs would also be welcomed. Supporting this request would enable the industry to cover the costs and take the revision of each of these QPs forward.
NFU representing you
Once there are sufficient contributions, the NFU plans to confirm this with the EA and secure places on the Task and Finish Group to enable us to represent you.
The EA will agree a cost estimate for the full project at this stage. We will attend workshops for the industry to enable us to gather further feedback, views and evidence you have (since responding during the review stage of consultation) and feed them into the process.
How to get involved
Please contact cGhpbGlwcGEuYXJub2xkQG5mdS5vcmcudWs= for further details about donations and which QP(s) you would like it to go towards; you can donate towards multiple QPs, and this may be influenced by whether your business produces, or is interested in, compost, digestate or poultry litter ash.
The NFU’s full response to the QP review, which was submitted on 28th February 2020, can be read here.