The Scottish Environment Protection Agency (SEPA) recently consulted on proposed standard conditions for all registration-level activities under the new Integrated Authorisation Framework (IAF). Read the full consultation document and accompanying guidance documents here.
On the 24th of November, the REA submitted a response on behalf of members. We provided feedback on key measures for composting, anaerobic digestion, and the use of waste on land. You can read our full response here..
Our response:
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- Recommended a risk-based approach to waste inspection and a tiered system for labelling and storage standards to reduce burdens on small and low-risk facilities.
- Highlighted the potential for inconsistent enforcement of odour and pollution control measures, advocating for a focus on significant impacts at sensitive receptors rather than detectability at site boundaries.
- Objected to overly stringent conditions for facilities processing less than 500 tonnes of biowaste, emphasizing risks to operational viability and urging adjustments to requirements for impermeable surfaces, drainage systems, and odour control.
- Opposed the proposed 1,000°C flare temperature for anaerobic digestion (AD) facilities, recommending alignment with the 850°C standard specified in the Industrial Emissions Directive.
- Called for flexibility in implementing leak detection requirements for earth-walled lagoons at AD sites where such systems are impractical.
- Criticised the six-month waste storage limit for land application in regions affected by weather delays, proposing flexibility in storage and testing requirements to accommodate operational challenges without compromising safety.
- Opposed a blanket requirement for waste enclosures, citing significant costs and insufficient risk-based justification, and recommended alternative measures to manage emissions and pollution, particularly for small or open-air facilities.
- Recommend amendments to conditions for biomass incineration to reflect operational realities while maintaining environmental protections