ENP0037

Written evidence submitted by the Anaerobic Digestion and Bioresources Association

Introduction

With our members, ADBA promotes the economic and environmental benefits of anaerobic digestion in the UK. We represent organisations from many sectors including AD operators, AD developers, AD equipment providers, water companies, farmers, food & drink retailers, waste companies, universities and more. AD is an environmentally friendly, cost-effective solution to dealing with much of what we think of as “waste”. Instead of burning it, or sending it to landfill, AD plants could potentially turn that waste into 30% of the UK’s household gas or electricity demand. This means less waste to landfill, stable energy prices, and fewer carbon dioxide emissions – with 35,000 potential jobs too. Biogas is essential for decarbonising our transport system and for improving the air in our cities and towns. The non-energy benefits of AD are numerous but as of yet they have not been linked to financial support mechanisms; support has only been provided for energy generated. It is time for the full range of benefits of AD to be recognised, for their role in achieving the following policy objectives, all key to the success of the 25 Year Plan:

• Reducing emissions from rotting manure, farm wastes and slurries, and replacing petrochemical derived artificial fertilisers, abating significant amounts of carbon and by replacing fossil fuel derived energy sources.
• Supporting farmers by diversifying their income, providing a steady income that is not dependent on fluctuating global commodity prices, and reducing input costs;
• Improving food security through profitable crop rotation and the recycling of essential crop requirements of Nitrogen (N), Phosphorous (P), Potassium (K) and trace elements through the spreading of digestate back to farmland, replacing the need for petrochemical-derived artificial fertilisers from overseas;
• Increasing organic matter, improving soil structure, reducing water demand, reducing soil degradation and run-off;
• Strengthening the rural economy by creating jobs: the AD industry currently employs 3,500 people and has the potential to employ a further 15,000 in the agricultural sector and 30,000 more widely; and,
• Developing low carbon technology and expertise to export to global markets.

Our response to the Environmental Audit Committee inquiry will focus on issues both important to our members, but also vital if we are to meet the Government’s stated goals of sustainably managed soils, zero food waste to landfill and a vibrant rural economy.

To what extent does the Plan set a sufficiently ambitious agenda across Government? How far do the objectives, targets and indicators set out in the plan reflect a higher level of ambition than existing targets (including European Union targets and the Sustainable Development Goals) and current performance? Are there any major gaps? AND To what extent does the Plan set out effective delivery mechanisms to ensure DEFRA, other Government departments and public bodies have the resources and responsibilities to implement it? Where should the Government seek agreement with the Devolved Institutions to ensure a common approach across the UK?

ADBA welcomed the publication of the 25 Year Environment Plan. In particular, we welcomed the intention for all of England’s soils to be managed sustainably by 2030 and the ending of food waste to landfill by 2030 However, we believe the deadlines could be even more ambitious than this and would encourage the Government to bring them forward. As we look to leave the European Union, and it is currently unclear if the existing compendium of EU environmental law will be kept once transposed in the EU Withdrawal Bill, it is important that ambitious targets and objectives are reflected in British proposals. The current proposal agreed by the EU Ambassadors is for all food waste to be separately collected by 31 Dec 2023, 7 years earlier than the Govt’s proposals.

In addition to our concerns around ambition, we are very concerned about the gaps between even the current level of ambition and implementation if we are going to meet our carbon targets by 2050. Responding to another significant environmental announcement, the Clean Growth Strategy, the Committee on Climate Change outlined a significant ‘policy gap’ in meeting our fourth and fifth carbon budgets. It should be noted that even this ‘policy gap’ assumed all current policies delivered their ambition, despite considerable doubt that many would.

ADBA believes this is also applicable to the Government’s approach to the 25 Year Plan and also our strategy to meet the UN Sustainability Goals. The CCC has called for ‘strong policies to deliver emissions reductions in agriculture’ to take effect by 2022. If the Plan for Nature is to succeed we believe that the Government should also take up this recommendation, and indeed may be under a legal obligation to do to meet its obligations under the Climate Change Act.

It is also vital however, that these plans – the 25 Year Plan and also related policies such as the Clean Growth Strategy - are widely accepted across the political spectrum to avoid each new administration shelving plans made by the previous one. Environmental protection and the ambitions of the Plan should be adopted together as long-term policies by major political parties and each stage of the development of specific programmes must find wide political consensus. The core policies and framework needs to be agreed and put into legislation binding upon future administrations just as the Climate Change Act and Carbon Budget have been.

The Plan sets out a natural capital-led approach and a principle of “environmental net gain” when undertaking development. What are the risks and benefits of adopting these approaches? What steps need to be taken during development and implementation to ensure they lead to positive environmental outcomes, especially in respect of biodiversity?

ADBA believes that a natural capital approach and principle of environmental net gain is a sensible one and consistent with the Government’s stated aim of leaving the environment in a better state than our generation found it. We believe fundamental to this strategy is a joined-up approach to waste management and the circular economy. This will be critical to achieving positive environmental outcomes, especially in biodiversity – improving our recycling rates and reducing waste to landfill by adhering to the food waste hierarchy would mean sending more inedible food waste to AD. A pertinent benefit of this to promoting biodiversity is the production of digestate – an organic fertiliser critical to improving and restoring our delicate soils.

Currently, under 50% of households in England have separate food waste collections[1]. For those that do not, their food waste is put in the general waste bin (black bin bags) and taken to landfill sites or for incineration/ energy recovery. DEFRA’s Energy from waste guide has more information on this. At the same time, the UK is on course to miss its target of recycling 50% of household waste by 2020. The household recycling rate actually went down last year. Of the 27 million tonnes of waste produced by UK households[2], 5.7 million tonnes (21%) is food waste[3].

The government needs to provide financial support to local authorities to introduce separate food waste collections across all authorities in order to reduce food waste to landfill and improve our poor recycling rates in England. The cost of introducing these collections has been estimated at £30m/ yr until all the authorities have the collections. It is also important that the government continue to incentivise the generation of renewable energy so we can meet our ambitious carbon targets. The recently published report on waste management by the London Assembly Environment Committee highlighted the lack of coordination between local authorities, the over-reliance on incineration and the under-utilisation of anaerobic digestion facilities. The Government should be encouraging greater collaboration and coherence in waste collection strategy with greater adherence to the food waste hierarchy as part of the 25 Year Plan, to keep more waste out of landfill.

Why?

Compared to the alternatives of energy recovery and landfill, separately collecting food waste for AD offers a cost-effective means of cutting carbon emissions:

1. When households receive a separate food waste collection, they often start to reduce waste and then need to buy less food, thus saving money. In Wales, over the period that separate food waste collections were introduced, the amount of food waste produced by households fell by 12%[4]. The average UK household currently wastes £470-worth of food per year [5].
2. The EU-funded research project VALORGAS outlined how food waste treated through AD generates 60% more energy than if the same food waste was put into a black bin bag and sent to an energy recovery unit[6]. Furthermore, the biogas produced by anaerobic digestion can be upgraded to produce green gas (biomethane) for the gas grid.
3. Treating food waste through AD produces a nutrient-rich digestate fertiliser, which is used in farming in place of artificial fertiliser such as nitrogen produced in factories. For example, each tonne of artificial nitrogen fertiliser produced in a factory results in the emission of 5.8 tonnes of carbon dioxide[7]. Using digestate can displace these emissions. As artificial fertilisers are often imported, this also reduces imports to the UK, improving food security.
4. The government’s Case for Greater Consistency in Household Recycling outlines how if all households in England had more similar waste collection systems, all of which would include food waste, then contamination of dry recycling would fall[8].

Value of digestate to the 25 Year Plan

Digestate from the anaerobic digestion process is a nutrient-rich biofertiliser. Use of digestate on farmland has been proven to maintain pH and soil fertility; improving soil fertility, crop yields and the availability of nutrients whilst, significantly, also reducing reliance on expensive, carbon intensive, imported artificial fertilisers. We believe that due to the commendable focus on soil health in the 25 Year Plan, there needs to a serious and targeted strategy for promoting the production and use of digestates to support farmers, help our soils and move away from expensive, imported artificial fertiliser.

• Digestate provides the essential crop requirements of Nitrogen (N), Phosphorous (P), Potassium (K) and other trace elements. It can provide a natural biological alternative to replace petrochemical-derived artificial fertilisers.
• For every tonne of artificial fertiliser that is replaced with digestate 1 tonne of oil is avoided and 108 tonnes of water.
• Due to pervasive use of artificial fertiliser, UK farming is subject to strict limits on how much Nitrogen can be spread.[9] Use of digestate as a biofertiliser is perfectly suited for agricultural nutrient management in that it provides for flexibility on application rate, application time, and application placement. Digestate can help return Nitrogen to land quickly if in liquid form or more slowly through use of the solid fraction.
• Use of digestate helps protect peat bogs. With British sources of peat continuing to decline, and phosphorous being a finite resource, digestate products provide an alternative source of nutrition for horticulture, parks and gardens. Use of digestate avoids the emissions caused by draining peat bogs. You can now buy digestate-derived fertiliser in over 200 Homebase stores.
• Returning phosphorous to land via digestate helps isolate UK farming from geopolitical instability and protects against volatile price spikes.[10] Phosphorous is important for UK food production, requiring 3kg per person per year[11] and the UK is an importer, with 75% of the world’s phosphate rock located in Morocco.[12]
• Digestate can also increase soil organic matter and prevent run-off, which can help slow soil erosion. This is important as soil damage, risk of run-off, drainflow, run-through to groundwater and erosion all effect conditions. Poor management practice and an over-reliance on chemical inputs has rendered 30% of the world’s arable land unprotected and less productive.[13]
• In some areas of the UK that have seen a sharp growth in intensive livestock farming phosphate build up is a concern. This is especially the case in Wales where due to growth in poultry farming there are risks to water supply contamination and land degradation. If animal slurry is sent to AD levels of phosphate returned to land can be regulated and up to 95% can be recovered.[14]

To what extent does the Plan set out effective delivery mechanisms to ensure DEFRA, other Government departments and public bodies have the resources and responsibilities to implement it? Where should the Government seek agreement with the Devolved Institutions to ensure a common approach across the UK?

We believe that more clarity is needed in terms of policy commitments from Government, with more effective delivery mechanisms and more ambitious timetables. However, we do welcome some aspects of the delivery plan - the five year reporting target is fair and reasonable, not so short as to have no time to measure impacts, not so long as to encourage shelving policies or delaying implementation.

There is evidence, most recently outlined in the 25 Year Plan for Nature as well as in the recently published Clean Growth Plan, that government departments are improving their joint working, especially between BEIS and DEFRA, a development we welcome. However, in our conversations with the government it can be hard to get officials and ministers in different ministries to break down silos and work collaboratively. This is critical when multiple government departments have to work together to improve cross-cutting issues such as air quality, waste management and the circular economy as outlined in the Plan.

Whilst Government can take the lead on implementing policies, it is extremely important to remember that the participation of the private sector will be critical to succeed in many of them. The ambition to increase resource efficiency and reduce pollution and waste, can be led by Government policies- but the implementation of these will largely fall upon the shoulders of local government and the private sector in respect of waste collection, farming and energy production in particular.

We believe that there is a significant opportunity to learn from the approach taken in Scotland and Wales in particular, where mandatory separate food waste collections already exist in law, and recycling rates are subsequently much higher than in England.

February 2018

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