First Call for Evidence in Waste Quality Protocol Review

Back in August the Environment Agency (EA) announced the beginning of a full comprehensive review of the End of Waste Framework. You can read our summary of the review in our previous blog post.

A Quick Recap

The agency will spend the next 12-18 months scrutinising the current Quality Protocols (of which there are 13), with 1 of 3 potential outcomes for each. Our summary explains what each of these outcomes could mean for you and your business as well as a worked example of rising costs.

Societal pressure, environmental concerns, technical advancement, and new legal standards have directed the EA to overhaul the End of Waste Framework, with QPs forming a key part of this. The QPs will be reviewed in stages with different groups of protocols being focused on at various times over the assessment period.

4R Group will update you throughout with progress of reviews and the ramifications of each decision that is announced.

First Call for Evidence

After a delayed start to the review process, it is now time to submit evidence to the EA for consideration. First up under the microscope are the Quality Protocols (QPs) for anaerobic digestate, compost, and poultry litter ash.

At this point no decision has been made regarding the continuation or withdrawal of these QPs. This stage is purely a gathering of information/views/evidence to be taken into account in the decision process. If it is decided that EA support is withdrawn or deemed necessary to revise a QP, further detailed calls for evidence will take place at that time.

For each of these 3 QPs, the EA would like views expressed as answers to the following questions:

• Issues of clarity – Is the text of the QP clear?
• Any abuse of the QP that you are aware of with evidence.
• Are there any aspects of the QP that you find onerous to meet and why?
• Are there any aspects of the QPs that you find too lenient and why?
• Evidence of unintended risk of pollution, or impacts on human health, or the environment despite QP being followed.
• Are there pre-existing, new, or developing waste processing technologies that could be included in the QP? Please provide evidence of their efficacy.
• Are there any uses and/or new end product markets that have developed since original publication that could be added?
• Has there been any revision of, or developments relating to, the product standards set out in the QP relevant to the use(s)? Have there been any new product standards published since original publication of the QP which you believe should be included?
• Are there any other relevant issues you wish to raise in relation to the QP?

Unique Issues

As well as the more generic questions above, there are specific questions for each individual QP that need to be answered (along with evidence). These more unique questions relate to concerns raised by EA staff during the initial stages of the review and are as follows:

Anaerobic Digestion QP:

• Do you think there is a market for the digestate that meets the QP requirements and if so, what is it?
• Do you think that QP compliant digestate has more potential to pollute than the comparator substance (i.e. pig slurry) and why? Do you think the QP compliant product is as stable in storage as that of the non-waste comparator?

Compost QP:

• Do you think that QP compliant compost contains the same contaminants e.g. plastic, organic contaminants including POPs (Persistent Organic Pollutants), as equivalent non-waste manufactured fertilisers and if so, why?

Poultry Litter Ash QP:

• Does the lack of a specification for the end use affect the market for this material?
• Are you a new PLA producer or a new PLA producer who was not involved in the design of the original QP e.g. on farm producers and if so, how are they/you using the QP?

Conclusions

This call for evidence represents a real opportunity for waste producers and businesses to put their case forward for the continuation of the QPs and to have their say in addressing environmental concerns. On the flip side, the outcomes could potentially cause some drastic and costly changes on the horizon, highlighting the need for industry wide engagement from the whole scope of producers.

How to contribute

Please e-mail your comments/evidence to resourcesframeworks@environmentagency.gov.uk with the title “Waste to Land QP Comments” in the title/subject box.

The deadline for correspondence is Friday 31st January 2020.

Keep posted to 4R Group for announcement updates and contact us for advice on QPs and permitting by emailing info@4r-group.co.uk. If you wish to have input into any of the QP reviews keep your eyes peeled for communications. You can contact the review team directly by e-mailing resourcesframeworks@environment-agency.gov.uk, or by forwarding your comments and input to the Organics Recycling Group at the Renewable Energy Association.