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The digestate challenge James Astor, Chairman Regen Holdings

July 2019

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Regen is an integrated waste management company, comprising:

Regen Holdings

Liquid organic waste management

company serving F&D and AD customers

1.5MWe anaerobic digestion plant,

processing up to 50ktpa of food waste

TWM company managing hazardous and

non-hazardous wastes

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Autumn spreading of digestates

The Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018

Spreading of PAS110 digestate regulated by the EA from April 2018

(ii) give rise to a significant risk of agricultural diffuse pollution, and

(b) takes into account the weather conditions and forecasts for that land at the time of

the application.

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Applying organic manure and manufactured fertiliser to agricultural land

4. (1) A land manager must ensure that, for each application of organic manure or

manufactured fertiliser to agricultural land, the application

(a) is planned so that it does not

(i) exceed the needs of the soil and crop on that land, or

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The issue

Crop need – defined by reference to RB209:

• No Autumn spreading to stubbles, cover crops

• Allowed: grass, OSR (30kgs/ha)

Autumn challenge: To empty winter storage before

“closed period” in arable areas

Winter challenge: More storage (timing, cost)

Spring challenge:

• Global warming - Warmer, wetter springs; “Beast from the East”

• More material spread in a shorter period

• Plant, staffing issues (equipment efficiency etc)

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Potential consequences

Enforcement, potential prosecution

Hydraulic lock – Winter 2019/20 – commercial impact

Upstream impact on customers

Minimum 6 months storage required (but no amount of

storage necessarily “enough”)

Increased risk of pollution/soil damage in the Spring

Needed: Time to comply

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Digestate – covered storage

From: COGAP July 2018

Different types of store:

• Tanks, silos

• Earth banked lagoons

• Ag Bags

Different types of covering:

• Impermeable – floating, tent, lid

• LECA (light expanded clay aggregate)

• Hexa covers

• Crust – fibre, straw

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Digestate – covered storage

More storage required immediately

• Covers not required today (exceptions)

• Future regulations on covering may not align with 2018 COGAP

• Retrofitting impermeable covers to lagoons difficult, expensive

Stores with impermeable covers:

• Gas build up, release

• Agitation – effectiveness, power, cost

Commercials: impermeable cover - £20/m3 - £100/m3 (e.g. £100k - £500k for 5000m3)

Timing:

• Find land; agree lease; secure planning

• Raise cash; procure store; build; commission

Needed: Time,

cash to comply

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Questions?

Contact: james.astor@regenholdings.com