Is the cost of compliance too high? Jeremy Jacobs, technical director at the Renewable Energy Association, takes up the argument…
Published in the CIWM Journal June 2013
We continually hear from the media and politicians of all colours, that if we are to pull ourselves out of the mire that we are currently experiencing, then it is imperative that industry is provided with the freedom to initiate growth and employment without excessive strictures. The overburden of regulation – or, more precisely, inappropriate regulation – falls within the boundary of this constrict and we are often reminded that we are to be regulated through a “lighter touch” mechanism.
There are a number of possible constraints which are applicable to our sector, including market confidence, investment security, regulatory constraints and Government policy incentives. If we look at each of these in turn and examine how our sector is affected and what we can do to mitigate the impacts, then this may provide a clue as to where the Organics Recycling Group (ORG, previously AfOR) needs to be focusing its attention in order to promote growth and confidence in our valuable industry in the future.
Market Confidence
Since the early use of green waste and food waste derived composts in the commercial and domestic growing media market, agricultural use as a fertiliser replacement and use in the landscaping arena, confidence and knowledge in the use of composts has grown considerably. WRAP has funded a wide range of growing trials which have resulted in enhancing the reputation of composts within all these markets. With a much better informed market and audience, we the compost and digestate processors (I include myself in this) cannot afford to be complacent. We must ensure that the quality message is promoted at all opportunities. PAS 100 and PAS 110 set a standard but should be considered as a minimum acceptable standard… the marketplace will ultimately dictate quality and price.
Investment Security
The composting sector is relatively mature now and although there has been continued investment in a number of new composting sites and expansion of existing ones, Government support for renewable energy has driven most organics projects down the anaerobic digestion route and this is now the preferred option for many. Having recently heard a spokesperson from the Green Investment Bank speak on this subject, it is clear that there are still plenty of hurdles that an operator will need to leap before this funding is made available and, most critically, although not surprisingly, markets for digestate and feedstock security feature high on the list of “must haves”
Regulatory Constraints
Without doubt, the ORG team spend more time in assisting members with regulatory issues than any other activity (other than possibly PAS 100/110 enquiries). The title of this article provides a pointer to the issue currently facing many sites. There has been an alarming increase in the attention that is currently being exerted to the biowaste industry by the regulator; the principle regulator for our sector in England is the Environment Agency (EA).
The sceptics amongst you may say that we are only getting what is due to those who fail to manage their sites in a responsible manner. I have no issue with proportionate and consistent regulation being applied in a manner which identifies issues, provides scientific evidence to support a call for change, consults with industry and finally allows a fair transition time for industry to change and adapt to the new regime. Failing to follow this tried and tested route gives rise to uncertainty, mistrust and worst of all, a lack of clarity for those who are regulated.
“We must ensure that the quality message is promoted at all opportunities. PAS 100 and PAS 110 set a standard but should be considered as a minimum acceptable standard”
The ORG has been working hard in recent years to build bridges with the EA through regular liaison meetings to improve its understanding of our issues and vice versa, and also to provide a forum for a healthy open and honest debate in a non-confrontational manner.
There are clear links between investor confidence and regulatory burden – too much of the latter will drive investment out of the country if the lack of certainty and clarity is not clearly visible.
In summary we require greater confidence that regulation is transparent; this will assist operator and regulator alike and promote a healthy environment for all to operate in.
