Southwest Environmental Limited

Aerobic Treatment of Manure - Bespoke Environmental Permit Application

A company in the south of England, who operate a facility that deals with animal manure. The manure is shredded and during its subsequent storage and bagging partial aerobic break down occurs. In the past the site has operated under a local authority mushroom compost license, but these are being replaced by environmental permits.

Southwest Environmental were engaged as Consultants to oversee the an Application for an Environmental Permit under the Environmental Permitting Regulations.

An assessment of the site was made to ensure that current arrangements were environmentally sound, meetings took place to discuss the needs of the client and the project time frame. A comprehensive third party data set was ordered, and reviewed, it was found that there were dwellings within 250 meters of the treatment facility, and a SSSI just a few meters away from the site boundary. These factors lead to the permit being of a bespoke variety.

At present the Environment Agency are unclear as to the risk posed to health by aerobic treatment of organic wastes, but all the same they requested an SSBRA, which had to be completed.

SWEL prepared supporting documentation for the application which was stipulated within the permit for a standard permit application these include:

- An Odour Management Plan

- A Site Condition Report

- An Environmental Management System

- An SSBRA (Site Specific Bio-aerosol Risk Assessment)

SWEL offer practical solutions to problems that may arise during the application process.

Application Fees for this permit were around £7,500, which we believe to be unrealistically high. This is why Southwest Environmental are asking for reduced application fees for permits. We have met with regional government representatives and been in discussions with the Environment Agency who have been on the whole . . . . inflexible.

Applying for a bespoke aerobic treatment permit takes around 12 weeks start to finish, this includes time for site visits, report writing, application submission to the Environment Agency and Processing time.

The Permit is "duly made" when the EA have received all of the information they need. The application then enters the determination stage, where the information content is scrutinized to make sure it has been written in accordance with Environment Agency guidance.

With regards to the quality assurance of the newly regulated scheme, it will be operated under  PAS100 standards.

Other compliance issues included The Animal Bi-product regulations.

The below section was written by a machine.

Technical Guidance: Bespoke Environmental Permitting for Composting

When a composting facility cannot meet the strict criteria of a Standard Rules Permit—perhaps due to sensitive receptors, large volumes, or specific waste types—a Bespoke Environmental Permit is required. This process is significantly more rigorous and requires site-specific technical evidence to demonstrate that the operation will not harm human health or the environment.

Key Components of a Bespoke Application

A successful application for a bespoke composting permit must address several high-level technical areas:

• Odour Management Plan (OMP): Composting is inherently odorous. We provide detailed Odour Impact Assessments and management strategies to mitigate impacts on local residents.
• Bio-aerosol Risk Assessment: For facilities within 250 meters of a sensitive receptor, a Bio-aerosol Risk Assessment is mandatory to evaluate the dispersal of fungi and bacteria.
• Fire Prevention Plan (FPP): The Environment Agency requires a robust Fire Prevention Plan to manage the risks associated with self-combustion and waste storage.
• Containment and Drainage: Design of sealed drainage systems and impermeable surfacing to prevent leachate from entering groundwater, often requiring a Groundwater Risk Assessment.

Regulatory Compliance and Best Practice

The application must align with the Environmental Permitting Regulations (EPR) and demonstrate the use of Best Available Techniques (BAT). This often involves complex ammonia emissions modeling or noise impact assessments depending on the site location and machinery used.

At SWEL, we leverage over 15 years of experience and 900+ completed projects to navigate the complexities of the Environmental Permitting process. We handle everything from the initial Pre-Application Advice to the final submission, ensuring your facility is both compliant and operationally efficient.

Why Choose a Bespoke Route?

While standard permits are faster, a bespoke permit provides the flexibility needed for innovative waste recovery operations. Whether you are dealing with animal by-products or industrial-scale green waste, a bespoke permit allows for tailored limit values that suit your specific business needs and geographical constraints.