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Small-scale Anaerobic Digestion: Are Planning Policies Getting in the Way?

As a proven and highly effective way of generating energy from waste, anaerobic digestion offers great potential to farmers for converting waste into biogas that can also be used to generate electricity. It produces a nutrient-rich digestate that can be used as a fertiliser into the bargain. It has the support of the coalition government. Both small and large scale AD plants are now up and running in many parts of the country. There’s a great untapped potential for the wider use of the technology. And yet it’s being held back by planning policies – both nationally and sometimes at a local level.

Organic wastes from farms are often stored in tanks before being spread to land. As well as not realising the value of this waste, the practice is undesirable because the waste may contain high pathogen levels. There’s also the potential for the carbon to strip oxygen from water courses. On top of that, ever-escalating fuel and electricity prices are increasing overheads and cutting into farmers’ profits.

AD is unique in being able to address all these problems in one. It converts waste into electricity for use on the farm to qualify for feed-in tariffs (FiT) payments, and it also creates a nutrient-rich end product that’s less pathogen-prone than conventional storage.

The government supports and promotes AD technology. Its 2011 DEFRA publication Anaerobic Digestion Strategy and Action Plan states its commitment to increasing energy from waste through AD. It outlines steps to increase its uptake, including an AD loan fund that offers some initial financial support.

Yet the UK lags woefully behind other European countries when it comes to AD. In Germany there are around 6,000 operational AD plants, mainly due to the realised level of government support. Their equivalents of the UK’s feed-in tariffs are higher, with greater initial funding, and more is done to remove potential barriers such as access to gas line connection. In Demark, similarly, the national energy policy includes a section on biogas along with a specific policy on funding that provides 30 percent of initial establishment costs. 

So if AD is such a viable and attractive form of renewable energy — not to mention a useful weapon in reducing reliance on fossil fuels and increasing energy security — what’s holding us back in the UK? 

National planning policy is the first issue. Before the Localism Act came into force in 2011, the previous (but now superseded) Planning Policy Statement 22 gave guidance on what to include in a planning application for AD developments and on what would be required of development control officers considering AD proposals. It stated that the people considering these applications should be trained and prepared to deal with applications for renewable energy technologies they might not be familiar with. It outlined potential AD planning issues and the detailed information that applications could usefully include.

But this specific guidance, along with Regional Spatial Strategies, was swept away by the Localism Act and by the National Planning Policy Framework (NPPF) that came into force in March 2012. Although the NPPF recognises the value of small scale renewable energy, it doesn’t make reference to AD or biogas directly, referring only to ‘renewable energy’ as a blanket term for all scales of renewable energy sources including AD.

Little or No Experience 

So how does this play out at a local level? The experience of some farmers (quoted in the recent Bywater Report) when dealing with planning authorities suggests that some local authority planning departments have little to no experience of dealing with AD applications, and as a result are likely to initially reject the application. “You would expect them to go away and do research,” said Richard Tomlinson of Lodge Farm, Wrexham, “but they don’t - and anything they don’t understand they say no to.” Clive Pugh of Bank Farm, Powys, said that “in general terms, if there is no guidance or the guidance has been unclear, the answer has been no.” 

We recently carried out our own research into local authorities (around 40 percent of the 357 English LAs including a good proportion of rural areas) and their planning policies on renewable energy and carbon emission reduction. It showed that relevant policies tend to focus on large-scale residential or commercial developments and associated renewable energy obligations — like variances on the Merton Rule where developments over 1000 m2 must have 10 percent of their energy usage provided by renewable energy sources.

On the whole they make general statements on renewable energy developments being encouraged - but without giving any guidance for developers or planning officers on what’s needed in an AD planning application. In many cases it seems likely that LAs will never have received an AD planning application, or had experience of the track record of a successful one. 

Now that Regional Spatial Strategies have been fully rescinded, many LA policies have simply defaulted to the new NPPF policies that say nothing specifically about AD. This leaves a real void of information and guidance, especially since the previous detailed and useful PPS22 is also now defunct.

Worse, it’s also far from clear in many cases what current LA policies are in place. Old documents are often kept online with no redirection to current policies. It can all add up to a lot of confusion and delays for anyone trying to understand local policy or submit a planning application. 

As Angela Bywater put it, writing for the Royal Agricultural Society of England in 2011: “planning policy guidance should be amended to clearly promote smaller scale AD on farms, citing what is and is not acceptable, so that it may be considered by planners directly, rather than using independent subjective and ambiguous interpretation of existing policy guidance.”

Yet there is hope — and still considerable interest in developing new small scale AD technology in the UK. A number of novel designs are now emerging, including a four stage horizontal farm-scale digester being developed by the Centre for Process Innovation under a Technology Strategy Board funded programme which is being supported by Wardell Armstrong, Derwentside Environmental Testing Services and CNG Services Ltd. Technology improvements through this type of research should improve accessibility and increase uptake.

In the meantime, it certainly is possible to secure planning permission and permits for AD — as proved by the twelve successful applications secured by Wardell Armstrong over the past five years. But to be sure of successful and timely planning permission and permitting it pays to get a consultant on your side with the right combination of expertise — a detailed understanding of the technology involved, and the complexities of the planning process. 

Lead image: Wooden fuel via Shutterstock

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