Calling for funding the Compost and AD Quality Protocols’ revision
You may be aware that the EA has announced that the Compost and Anaerobic Digestate Quality Protocols need to be revised to enable the EA to continue supporting them (i.e. for the end of waste positions to remain). We are keen to work together with industry and the EA to take these revisions forward and thereby ensure we retain end of waste options for waste-derived composts and digestates[1]. It is also an opportunity for stakeholders to work together to improve these QPs.
Please see this Q&A document for more details on the revision process and the topics the EA consider need to be addressed. This will affect producers in England and potentially Wales and Northern Ireland too.
The EA has stated that these revisions will need to be paid for by industry. In response to the announcement, ADBA and REA 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 forthcoming from 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 and digestates 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 needed
We, the above 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 any 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.
We 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/slurries or co-digests them with energy crops. Sites processing larger volumes may wish to contribute more. We also welcome contributions from organisations who are not producers of end of waste materials covered by these QPs. Supporting this request would enable us to cover the costs and take the revision of each of these QPs forward. We are happy to receive all donations so please contact us to discuss.
REAL have offered a separate contribution.
Once we have sufficient contributions we plan 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 then plan to arrange 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 email your primary association contact (details below) with the attached form confirming the amount and which QP(s) you would like it to go towards; you can donate towards one or both, e.g. this may be influenced by whether your business makes or is interested in compost and/or digestate. Please also include purchase order numbers if needed and invoicing details. Please confirm your donations by 26th March.
The small print
Following the confirmation of industry’s support, the trade associations will collaborate so that REA will issue an invoice to each business for their contribution. Funds raised will be administered through the REA accounts but will be accounted for separately from other REA income. The money raised will be ring-fenced for the Compost or AD Quality Protocol revision. Funds for each QP will be accounted for separately and only used for that QP. The funds raised will be only used for either paying for the EA’s revision process directly, for paying for external expertise where needed on specific topics and a small admin fee to cover the management of financial contributions. Any surplus funds at the end of the revision process for each of these QPs will be refunded proportionately to those who donated them (subject to an admin fee).
Contact details
REA – Jenny Grant, [email protected]
ADBA – Leanne Williams, [email protected]
CIWM – Tina Benfield, [email protected]
ESA –Julien Grolée, [email protected]
[1] The EA have also stated that the Poultry Litter Ash QP needs to be revised if industry wants to keep an end of waste rule set for the wastes it covers. This letter is not requesting funding for revision of that QP, so if you have interest in this one, please contact your Association.