The Anaerobic Digestion & Bioresources Association (ADBA), the UK’s trade body for AD, has today labelled the proposals in the Environment Agency’s (EA’s) consultation on its Strategic Review of Charges as ‘unjustified’. 

The changes proposed in the consultation include significant increases in the majority of charges associated with environmental permitting (including application fees and ongoing annual subsistence fees), which will have financial implications for all new and existing AD operators who operate under environmental permits in England. It is thought that in some cases, the increases will double the existing charge. The changes are due to be implemented from April 2018, just two months from the conclusion of the consultation period.

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This means that farmers applying for a new permit for activities related to an AD plant running off agricultural residues and crop feedstocks will see the standard fee rising from £1,630 to £2,641.

Additional fees would then be incurred for noise, pest management and odour plans, taking the total cost of applying for a new permit for a plant with a capacity of less than 100t/day from an estimated £8,000 to more than £16.000.

The Environment agency also plan an increase in the annual fee for small on-farm AD plants from £1,580 to £3,809.

Charlotte Morton, Chief Executive of ADBA, said:

“Whilst ADBA supports the need for a well-resourced, effective regulator, the proposed increases in the Strategic Review of Charges are extremely steep and their implementation date of April 2018 will be very challenging for AD operators to meet. As a matter of priority, we urge the EA to consider extending this implementation date or, as a minimum, adopt a phased approach, allowing both themselves and the industry to be fully prepared for any changes.

“AD operators are already under increased financial pressure and even small cost increases will result in greater strain and could have a detrimental impact. Should the proposals lead to reduced enthusiasm in investing in the industry or limit operators’ ability to invest in their operations, this could be detrimental to the environment and to AD’s ability to meet vital policy goals.”

ADBA’s comments come after it submitted its response to the consultation last week.

The EA’s consultation was published shortly before ADBA launched the new AD Certification Scheme, an industry-led initiative designed to support the AD industry to improve its operational, environmental, and health and safety performance, in December 2017. The scheme gives AD operators the opportunity to demonstrate good practice in the running of their plants and has been welcomed by the EA, who called it ‘a positive intervention by the industry to improve performance in the anaerobic digestion sector’.

Ms Morton added:

“We are working closely with the EA on our new AD Certification Scheme, which we believe will improve the AD industry’s performance and justify reductions in annual subsistence fees for certified operators. Many of the scheme criteria are similar to those included in EA site audits, and this presents an opportunity to reduce the EA’s regulatory effort. We look forward to working with the EA to monitor the scheme’s impact and secure regulatory benefits for certified operators through ‘earned recognition’.”