Fertiliser & Regulation - Bryan Lewens (Andigestion Ltd)
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Transcript of Fertiliser & Regulation - Bryan Lewens (Andigestion Ltd)
Farming FuturesFarm Biogas Developer
30th June 2009Fertiliser and Regulation
Bryan Lewens
Holsworthy Plant Jan 2001 Construction of plant
Planned to process mainly animal manures23 dairy farms and 1 layer unit
Pasteurisation 70oC for 1 hour to kill animal pathogens.
Planning Permission to take 20% food wastesAnticipated benign regulation
But Feb 2001 – Foot and Mouth Disease. Plant subject to Integrated Pollution, Prevention, Control
(IPPC regulations Environment Agency ) May 2003 Animal By-Products Regulations- DEFRA Animal
Health October 2005 Digestate spreading to land as bio-
fertiliser . EA Notifiable Exemptions subject to fees. 2007 Environment Agency fees reach £80,000+/annum
May 2008 Food “Waste” only plant- throughput reduced.
Digestate- Analysis(courtesy Owen Yeatman )
Dry Matter* 4.5% pH* 7.9 Total N 3.5 kgs/M3 31 units/1000 gallons
NH4 N** 2.5 kgs/M3 23 units/1000 gallons
P2O5 1.0 kgs/M3 9 units/1000 gallons
K2O 2.3 kgs/M3 20 units/1000 gallons MgO* 0.8 kgs/M3 7 units/1000 gallons SO3 * 0.4 kgs/M3 4 units/1000 gallons
*Estimates BL
**Potentially Crop Available N 70%Total N (Source OY)
NB. Typically cow slurry 50% Total N Potentially Crop available.
1st Cut Silage Spreading Rate (m3/ha) = 35
Digestate applied on 15th March - Shallow Injection
Nitrogen (N)
Phosphate
(P2O5)
Potash
(K2O) Value
Estimated total nutrients in digestate (kg/m3) 3.5 1 2.3 £4.95
Estimated available nutrients in digestate (kg/m3) 1 2.8 1 2.3 £4.54
Requirement for 1st cut silage (kg/m3) 2 120 40 80 £176.23
Calculate digestate supply of potentially plant-available nutrients (kg/ha) 98 35 81 £158.89
Calculate supply of plant-available N after NH3 and
NO3 losses (MANNER) (kg/ha) 79 35 81 £147.88
Calculate inorganic fertiliser need (kg/ha) 41 5 -1 £28.35
Total N/hectate applied (kg/ha) 123
Digestate Spreading June 2nd 2008
Grass cover June 30th
Regulation SituationKey regulation is still under consideration
DEFRA consultation on Waste Exemptions delayed which in turn has delayed
Implementation EA Standard permits covering AD plants, digestate storage and spreading of wastes. Now out for consultation (ends August 28th 2008) but subject to DEFRA decision on Exemptions.
DEFRA is keen for AD to develop- seen as benefit in NVZs and in treating organic waste.
What is “Waste”- legally“Any substance or object the holder discards,
intends to discard or is required to discard" is WASTE under the Waste Framework Directive
Material continues to be a waste until “fully recovered” e.g Holsworthy digestate spread on land as a fertiliser.
If non waste materials are mixed with “waste” materials, the mix is waste
Economic value is not relevant to waste statusLegal Definition of “waste” can change
Animal ManuresIn April 2008 the EA published a guidance note:
Manures and slurries spread to land are not “wastes”But if designated for AD they are “wastes”The resultant digestate is therefore “waste”
Following concerns raised during the Exemptions Consultation lobbying by NFU/CLA/REA
In December 2008 this was revisedManures and slurries designated for AD are still
“wastes”As a result of AD the process improves the fertiliser
qualities and if spread to land in the same way as manures and slurries the digestate is not “waste”. Recovery achieved in the digestion process.
ImplicationsDigestate from AD plants processing animal manures
and slurries and energy crops (non wastes) are not subject to Waste regulations.EA Notifiable Exemptions for spreading wastes are
expensive to apply for and require time and expertise (FACTS) to administer- not required
No major regulatory issues over storage- (as for slurry) Less likelihood of public concerns over using “waste” on
agricultural land
Very small farm (non waste) AD plants are likely to be able to operate under a Simple Exemption.Little or no cost registration with EA?Question over economic viability. Thermal input <1.5MW?
Implications (cont)Larger plants will require Standard Rules Permit
Standard rules if plant specifications fit. (Current EA Consultation)
Subject to application fee, maintenance fee, surrender fee.
Slurry being temporarily stored prior to digestion should be exempt .
But:-If any controlled “wastes” are added to the intake
material all the resultant digestate becomes waste and is subject to waste regulation.
Farm regulations.
Farm Regulation- Cross-Compliance
Good Agricultural and Environmental conditions (GAEC 3) Waterlogged soil- e.g making a mess when spreading.
Nitrate Vulnerable Zones (70% England)Lot of records to be kept starting April 2009 in existing NVZsOrganic Nitrogen limits
Farm 170kgsN/ha/year- animal originField 250kgsN/ha/12months- all organic material spread
Storage Required- 6 months for pig and poultry manure 5 months for cattle and others
Closed spreading periods (>30% N availability)Grass Tillage
Sandy/Shallow soil Others Sandy/Shallow soil Others1st Sept- 31st Dec 15th Oct-15th Jan 1st Aug-31st Dec 1st
Oct-15th Jan
NVZs (cont) Digestate Implications
Owen Yeatman8000 tonnes cow slurry1500 tonnes maize silage1500 tonnes grass silage.
1. Closed period enforced >30% available N2. Storage 5 months using cow slurry (6
months if include pig slurry as substrate)- for all digestate.
NVZs – Digestate (cont)3. N Farm Limit.
1. Own farm only- standard calculation (DEFRA leaflet 5)
2. Jointly operated digester- considered an import and supplier should notify you of total N content. Otherwise analyse (leaflet 3)
3. If 100% animal manure then use total N content
4. If mixed with other materials then supplier should advise you of animal proportion so you can calculate imported animal N.
NVZs – Digestate (cont)Can estimate on proportion of input
For Owen Yeatman 73% of 3.5kgsN =2.56kgs NCan make more detailed calculation if relevant data available
Crops low in N could be that 85% of N is from animal sourceWhere no data available or for simplicity take 100% of sample
result.
4. Organic N field limit.If digester serves your farm only use standard figures (leaflet 8)Imported N advised by supplier or sample and analyse.
5. NmaxCalculate animal N as for farm limit.Crop available portion use highest percentage applying to
livestock manures in feedstock. Eg. Cattle 25% until 2012.Ignore non-livestock N
NVZs – Digestate (cont)6. Nitrogen Planning
Must take into account all of the nitrogen in the digestate that will be available to the crop.
Starting point potentially available N- 70%(+) of total N
Owen Yeatman 2.5kgsN potentially available.Then estimate losses during storage and spreading.
Other IssuesPre-storage of slurry coming on to a farm for AD
processing to be covered by Standard Permit.DEFRA still to decide in case of Simple
Exemptions.Farmer can take his slurry/manure to another
farm for AD processing.If done by another farmer must register with EA
as a waste carrier- Currently free if farm waste.
Mesothilic AD will kill many pathogens and weed seeds but risk of transfer to other farms not regulated.
Farm RegulationFor a relatively simple life – Manures and energy
crops.One estimate of the regulation covering biological
treatment of controlled wastes. -7kgs documentation. Detailed understanding of the regulation covering
any planned operation is essential.- If in doubt take advice
Regulation is constantly changing- Anticipating change at the planning stage may save costs later.
This applies to England and Wales- Scotland differs.
Controlled Waste Regulation“Waste” plants subject to Environmental
Permitting. Smaller plants subject to Standard Rules
Permits. Restrictions on Intake materials (Animal By-
Products)Larger plants subject to Bespoke Permits
(e.g.Holsworthy)Adopt Best Available Technique (BAT).Emissions Controls.Expensive compliance costs and relevant
expertise required
“Duty of Care”Code of Practice that places a Legal Requirement on
all those holding controlled wastes to ensure that:Wastes are safely cared for.Written information is provided to ensure that anyone
dealing with the waste can comply with their dutiesWaste is only transferred to people authorised to
receive itPrevent waste causing pollution or harm whilst under
your control or under subsequent control until recovered.
Those that supply you with waste want to be sure that you are acting compliantly.
“Wastes” of Animal OriginSubject to Animal By-Products Regulation
AD plants can accept:Low risk Category 3 materialMilk product Animal Manures.
“Wastes” of Animal Origin (cont)Plant must be ABP compliant.
All material pasteurised 70oC for 1 hourChopped- particle size <12mmPlant will need to meet design requirementsSubject to Hygiene Procedures. (cross-
contamination)Routine inspection by Animal Health VetsSubject to audit trail from entry to plant to land
spreading.21 day grazing ban following spreading. Farmer records subject to Animal Health
inspections.
“Waste” Digestate Storage- off siteSubject to Environmental Permitting
Planning may be an issueEP Application + FeeAnnual EP maintenance feeWorking plan- to ensure facility correctly
managed
Standard Rules Permit for Digestate Storage .EA Consultation period ends August 28th 2009Expected to come into forceApril 2010
“Waste” Digestate SpreadingEA Controls over spreading waste to landPara 7 Notifiable Exemptions.
Must demonstrate agricultural or environmental benefit.For digestate generally to provide nutrients to meet crop
demand.Code of Good Agricultural Practice (COGAP)-Nitrogen limitsNVZ regulations Submit considerable amount of information with application.Each exemption is for up to 50ha and has to be renewed
annually.Fee must be paid- currently £575 for new applicationSpreading records must be kept for 2 years.
To be replaced by Standard Rules for mobile plant for land spreadingPermit Digestate likely to be covered from Oct 2011.
Anticipate it to be more onerous than Exemption.
Certificate of Agricultural BenefitSigned by FACTS qualified person.Waste Analysis- nutrients and heavy metalsStandard Soil Analysis (every 4 years)Crop nutrient demand (RB209)
Sets limits on nutrient amounts and timing.Cereals no available nitrogen requirement in seed
bedPhosphate soil index 4+
No phosphate requirement for most crops
Quality ProtocolQuality Assurance for digestate, approved by
food chainProcedures and Standard (PAS 110) whereby
digestate would cease to be a “waste when it leaves the plant”.
Still awaiting final go ahead from Europe.Some remaining issues over tests required.Not an easy option.
Defaults to waste if not correctly used.Standards and procedures subject to independent
auditSupervision of on farm records?
Useful LinksNVZ guidancehttp://www.defra.gov.uk/environment/water/quality/nitrate/help-
for-farmers.htm
Standard Permitshttp://www.environment-agency.gov.uk/research/library/
consultations/36989.aspx
Duty of carehttp://www.defra.gov.uk/environment/waste/legislation/
duty.htm#code
Useful Links (cont)EA Para 7 Exemptionshttp://www.environment-agency.gov.uk/business/topics/permitting/
34782.aspx
Environmental Permittinghttp://www.environment-agency.gov.uk/business/topics/permitting/
32320.aspx
COGAPhttp://www.defra.gov.uk/farm/environment/cogap/
Animal By-Products Regulationhttp://www.defra.gov.uk/animalh/by-prods/wastefood/compindx.htm
QP/ PAS 110.
http://www.biofertiliser.org.uk/certification/england-wales/quality-protocol
Thank You