ADBA PERMITTING WORKSHOP
27 March 2013
Stephen Barnes, Technical Director, Wardell Armstrong
Introduction
• Regulatory Background
• Exemptions
• Standard Rules Environmental Permits
• Bespoke Environmental Permits
• Fees and timescales.
Regulatory Background
• Environmental Permit required to deposit, treat, keep and dispose of
waste (unless lawfully exempt)
• Environmental Permitting (England and Wales) Regulations 2010
o
Schedule 1 includes AD plants that treat >10 tonnes per day of
animal carcasses or animal waste (up to 6 April 2012 gas
engines with a net rated thermal input ≥3MW also fell under
Schedule1)
o
Schedule 3 lists exempt activities, which includes small scale AD
plants
o
Schedule 9 list waste operations, which includes those AD plants
that do not fall under exemption or Schedule 1.
Regulatory Background
•
Environmental Permitting (England and Wales) (Amendment)
Regulations 2013 implement the Industrial Emissions Directive (IED)
• Sites that fall under the IED also fall under Schedule 1, however there are
phase-in dates
• Implementation of IED, from:
o
7 January 2013 - at new sites that fall under the Directive
o
7 January 2014 – at existing Schedule 1 sites that fall under the
Directive
o
7 July 2015 – at existing sites (not previously Schedule 1) that fall
under the Directive
Regulatory Background
•
The AD of non hazardous waste at a site with a capacity ≥100 tonnes per
day falls under the IED and therefore Schedule 1
• Schedule 1 activities subject to additional permitting requirements, Best
Available Techniques, Energy Assessment, Raw Materials Assessment
• Existing sites that fall under the IED will require a variation of the
Environmental Permit (possibly an Environment Agency administrative
variation, otherwise an application by the Operator).
Regulatory Background
Environmental Permitting (England and Wales) Regulations 2010, as amended
Schedule 1
AD≥100 tonnes per day
AD > 10 tonnes per day of
animal waste
≥ 50MW (Part A)
≥ 20MW - <50MW (Part B)
Schedule 9
Other AD Waste Activities
not falling under
Schedules 1 and 3
Environmental Permit
Schedule 3
T24
T25
U10
U11
Exemption
Exemptions
• Register exemption, renewal required every 3 years
• Exemptions for on farm AD (T24), off farm AD (T25) and
spreading digestate on land (U10 & U11)
• Comparatively small schemes only (gas engines with a net rated
thermal input less than 0.4MW)
• Maximum waste storage and treatment at any one time: on
farm AD - 1,250m³; off farm AD 50m³
• Spread digestate on land to confer benefit - up to 50 tonnes per
hectare in any 12 months period
• Exempt activity must not cause pollution, harm or nuisance.
Exemptions
Cockle Park Farm, photo courtesy of Newcastle University
Exemptions
• Small scale activities, e.g. Cockle Park Farm
o
University of Newcastle upon Tyne
o
350kWe
o
Gas to a boiler for heat production
o
Heat supplied to farm buildings
o
Plant installed by Marches Biogas
Environmental Permits
Environmental Permits
Standard Rules
Bespoke
Schedule 1
Schedule 9
On-farm Installation
Off-farm Installation
On-farm waste Operation
Off-farm waste operation
Schedule 1
(Subject to BAT etc)
Schedule 9
Standard Rules Environmental Permit
•
New Standard Rules permits published in January 2013 (SR2012 No 09,
SR2012 No 10, SR2012 No 11 and SR2012 No 12)
•
Replace previous Standard Rules permits SR2010 No 15 (off-farm AD)
and SR2010 No 16 (on-farm AD)
•
SR2010 No 15 (off-farm AD) and SR2010 No 16 (on-farm AD) are no
longer available for new sites
•
Existing sites under Standard Rules permits for AD will be phased-in to
the new Standard Rules
•
Phase-in details to be finalised by the Environment Agency.
Standard Rules Environmental Permit
•
•
Generic criteria for Standard Rules permits (SR2012 No 09, SR2012 No
10, SR2012 No 11 and SR2012 No 12)
o
Not within 10m of any watercourse
o
Not within 50m of any well, spring or borehole used to supply water
for human consumption
o
Not within a Groundwater Protection Zone 1
o
Not within a specified Air Quality Management Area
Gas engine emission limits (NOx = 500mg/m3, CO = 1,400mg/m3,
SO2 = 500mg/m3, total volatile organic compounds = 1,000mg/m3.
•
No emission limits for boilers, back up flares, pressure relief valves.
Standard Rules Environmental Permit
•
Specific criteria for Standard Rules permit SR2012 No 09, on-farm
installation
o
Not within 500m of a European Site or SSSI (excluding geological SSSI)
o
Minimum stack height of 3m
o
Not within 200m of a sensitive receptor unless the stack height is at least 7m
or the effective stack height is at least 3m
o
AD capacity over 100 tonnes per day
o
Up to 100,000 tonnes per annum of farm waste only (or a combination of
farm waste & non waste)
o
Net rated thermal input of gas engines <5MW
o
Permit includes physical pre-treatment of wastes, gas drying
cleaning & storage & upgrade to biomethane).
Standard Rules Environmental Permit
•
Specific criteria for Standard Rules permit SR2012 No 10, on-farm waste
operation
o
Not within 200m of a European Site or SSSI (excluding geological SSSI)
o
Minimum stack height of 3m
o
Not within 200m of a sensitive receptor unless the stack height is at least 7m
or the effective stack height is at least 3m
o
Farm waste (or a combination of farm waste & non waste) only
o
AD capacity less than 100 tonnes per day (therefore < 36,500 tpa)
o
Permit includes physical pre-treatment of wastes, gas drying
cleaning & storage & upgrade to biomethane).
Standard Rules Environmental Permit
•
Specific criteria for Standard Rules permit SR2012 No 11, off-farm
installation
o
Not within 500m of a European Site or SSSI (excluding geological SSSI)
o
Not within 200m of a sensitive receptor
o
Minimum stack height of 3m
o
AD capacity over 100 tonnes per day
o
Up to 100,000 tonnes per annum (includes a much wider range of
wastes than on-farm Standard Rules permits)
o
Net rated thermal input of gas engines <5MW
o
Permit includes physical pre-treatment of wastes, gas drying
cleaning & storage & upgrade to biomethane).
Standard Rules Environmental Permit
•
Specific criteria for Standard Rules permit SR2012 No 12, off-farm waste
operation
o
Not within 200m of a European Site or SSSI (excluding geological SSSI)
o
Not within 200m of a sensitive receptor
o
Minimum stack height of 3m
o
AD capacity less than 100 tonnes per day (therefore < 36,500 tpa)
o
No more than 10 tonnes per day of animal waste
o
Permit includes physical pre-treatment of wastes, gas drying
cleaning & storage & upgrade to biomethane).
Bespoke Environmental Permits
Reliance Street, photo courtesy of Viridor Laing
Bespoke Environmental Permits
•
Sites that do not fall under exemption or Standard Rules
•
Detailed application, including quantification of all emissions (H1)
•
Air dispersion modelling may be required in some cases
•
Use of Best Available Techniques for certain activities (known as Schedule 1)
•
Risk based assessment to determine application fee (EPR OPRA)
Bespoke Environmental Permits
Westry AD Facility, photo courtesy of Local Generation Limited
Timescales and Costs
• Exemptions
o Complete form and submit to Environment Agency
o Environment Agency should register exemption within 5 working days
o Registration is free
• Standard Rules Environmental Permit
o AD waste operations - £1,590 application fee (on-farm & off-farm) and annual subsistence fees of
£1,540 (on-farm) or £2,420 (off-farm)
o AD installations - £1,900 application fee (on-farm & off-farm) and annual subsistence fees of
£1,990 (on-farm) or £3,330 (off-farm)
o Environment Agency has 13 weeks to determine application once Duly Made (should take less)
• Bespoke Environmental Permit
o Application fee based on EPR OPRA (experience of AD indicates at least £7,000)
o Annual subsistence fees based on either EPR OPRA or fees and charges scheme
o Environment Agency has 13 weeks to determine application once Duly Made