NFU environment policy adviser Philippa Arnold says the result of the changes is that some farms could be moved over to bespoke permits if they do not meet new criteria for standard rules permits (SRPs).
Ms Arnold says: “Standard rules permits are relatively easy with low admin requirements. They involve declaring you are doing everything correctly and are a voluntary permit.
“Bespoke permits can be quite expensive.”
Proposed changes to standard rules are also likely to cost operators and include a requirement to cover all storage lagoons and tanks such as those containing digestate and dirty water. The EA says it recognises, for existing facilities, adding a cover may be cost prohibitive. However, it suggests adding a floating cover may be a viable alternative.
Ms Arnold says, currently, the definition of a cover is unclear. “It could be a crust, chopped straw or something physical. NFU takes issue with retrofitting covers to existing stores as it may invalidate the warranty and the store may not be designed to bear the weight of the cover – it could be dangerous.”
Other proposed changes include a requirement for an engineer to visit AD sites to check secondary containment and lagoon structures meet Construction Industry Research and Information Association (CIRIA) standards and to amend operating techniques requirements.
“We could be talking costs of £1,000s right up to £100,000s,” said Ms Arnold.
She adds that while industry bodies have been consulted, there is a feeling that there has been a lack of communication with plant operators about the changes.
Standard rules permits contain one condition which refers to a fixed set (or sets) of standard rules that an AD operator must comply with. These define the activities that an operator can carry out. They also specify necessary restrictions on those activities, such as emission limits or the types of waste or raw materials that can be accepted at the sites. If operators can meet the rules they can decide to apply for a standard permit. If they cannot meet the rules, they must apply for a bespoke permit. Standard permits can be issued more quickly and cheaply than bespoke permits.
Source: Environment Agency
The consultation: Standard rules consultation no 20: revision of standard rules sets for biowaste treatment ends on February 28 (an extension from the previous date of January 13). To respond visit: consult.environment-agency.gov.uk/environmental-permitting/standard-rules-consultation-no-20/