Call for Evidence : ​Non Waste Anaerobic Digestion over 100 tonnes per day: Permit technical requirements ​

Closes 9 Jan 2026

Opened 6 Oct 2025

Overview

This is a call for evidence on the proposed technical requirements for plant carrying out non- waste anaerobic digestion (AD) over 100 tonnes per day. As an evidence-led organisation SEPA is keen to ensure that operators have the opportunity to provide detailed information via this call for evidence that we can draw on to develop our consultation on proposed permit conditions for anaerobic digestion (AD) sites handling more than 100 tonnes per day. These technical requirements will inform the permit conditions for anyone carrying out this activity after 1 April 2028. 

The non-waste AD under 100 tonnes per day registration standard conditions were consulted upon in September 2024 and published on our website  on 5th August 2025 and are aligned with the waste AD registration requirements. 

We recognise that AD activities are important to the circular economy and net zero. AD using waste feedstocks has been regulated for decades because of its potential to cause environmental harm such as impacts to the water environment, air quality and nuisance issues (i.e. odour). After extensive engagement and consultation, the Environmental Authorisation (Scotland) Amendment Regulations 2025 introduced regulation for anaerobic digestion that use non-waste feedstocks (for example specifically grown crop feedstock) as a schedule 26 Part 3 Chapter 5 ‘other emissions activities’.   

The published Scottish Government Business Regulatory Impact Assessment (BRIA) recognised that this activity carries similar risks to the environment as waste AD.  Bringing non-waste AD into the Regulations provides a consistent regulatory framework for all operators of anaerobic digestion plant, regardless of feedstock, and ensures that regulation is appropriate, proportionate and equitable based on risk to the environment. 

Who does it affect? 

Anyone carrying out the anaerobic digestion of non-waste feedstock over 100 tonnes per day. The published BRIA estimates that there are currently between 10 to 20 AD plant in Scotland using only non-waste material in their digestors that are likely to be affected.    

Currently there are 25 waste-fed AD Plants in Scotland that must comply with these requirements so introducing the requirements to non-waste AD will ensure consistency across the sector. 

How will it affect me? 

If you operate or plan to operate an AD plant that processes non-waste feedstocks (e.g. by-products from another process or purpose grown energy crops such as sugar beet, rye, etc.) with a capacity exceeding 100 tonnes per day you must have an environmental authorisation by 1 April 2028. This authorisation will contain conditions to ensure that the environmental risks from the process are managed and minimised.  

As outlined in the Scottish Government and SEPA EASR consultations, the intention is to align the regulatory requirements for all AD plant to enable a level-playing field in environmental protection. We therefore intend utilising as a baseline the same technical requirements that waste AD operators (over 100 tonnes per day) must comply with, where relevant, to non-waste fed AD plant). These are called the Waste Treatment Best Available Techniques (BAT) Conclusions.  

The operators (and prospective operators) of non-waste AD activities will incur charges for the new authorisations and potential increases in capital investment to meet the required technical standards by 1 April 2028. 

What do I need to do? 

Annex 1 summarises the waste treatment BAT conclusions which we have assessed as being applicable to non-waste AD activities. You should read the Waste Treatment BAT Conclusions for each of these and refer to our supplementary interpretational guidance on the waste treatment BAT conclusions which expands on what each BAT conclusion means. Where the term ‘waste’ appears in relation to input feedstock for the AD process you should consider this in the context of your non-waste feedstock.  

You may also find it helpful to refer to the main BAT Reference document for Waste Treatment for further information. 

We are asking operators and suppliers of non-waste AD plants to read these documents and consider: 

  • if they already comply,  

  • if they do not already comply, how they would apply each BAT to their existing facility 

  • and if relevant, can each BAT be applied to a new build non waste AD plant.  

We want to know where sites are currently compliant as well as where there are gaps or issues with meeting the required standard.  

Timeline 

The call for evidence will run until 9 January, during which we will also engage with operators. 

In early 2026, drawing on the evidence received, we will consult on proposed permit conditions for non-waste anaerobic digestion (AD) sites handling more than 100 tonnes per day. 

By summer 2026, we will publish the final non-waste AD permit templates and guidance. 

From 1 December 2027, operators will be required to apply for a permit or registration. 

From 1 April 2028, all non-waste AD sites must hold a permit or registration under EASR in order to operate. 

How to respond 

It is important that detailed and robust evidence is provided where there may be problems meeting compliance with the relevant waste treatment BAT conclusions by 1 April 2028. We have provided a template to collate evidence to ensure consistent assessment and robust analysis of the evidence provided. 

We would prefer you to respond to this call for evidence using our on-line survey. 

Or If you prefer you can respond by sending an email to industrialactivities@sepa.org.uk if submitting an email response, please fill out the Submission (excel) spreadsheet

Responses must be submitted by midnight on the 9 January 2026, earlier responses are welcome. 

Handling your response  

We would like to know if you are happy for your response to be made public. If you ask for your response not to be published, it will be regarded as confidential and treated in accordance with SEPA’s published Privacy Policy

How we use your feedback  

As Scotland’s principal environmental regulator, our purpose is to protect and improve Scotland’s environment in ways that, as far as possible, also contribute to improving health and well-being, and achieving sustainable economic growth. Our Corporate Plan 2024-2027 sets out our strategic ambition and priorities. Our Annual Operating Plans set out how we will implement our priorities every year 

In delivering these priorities we engage with those who have an interest in and/or are affected by our regulations and duties. This is your opportunity to provide evidence to inform our proposals. The feedback we receive helps us to understand what matters most to people and how we can deliver our duties efficiently and effectively.  

Following this call for evidence, we’ll review the information we receive and use it to develop our proposals, including how we regulate through permits, before consulting on these proposals.  

Supporting information

Guidance on completing this call for evidence

General:
Waste Treatment 
BREF:
A link to the Waste Treatment Bref can be found here.
Waste Treatment
BAT Conclusions:
A Link to the Waste Treatment BAT Conclusions can be found here. 
SEPA Interpretational Guidance: A link to the SEPA Interpretational Guidance can be found here.
What activities this call for evidence relates to: This call for evidence applies to all Operators undertaking activities defined within paragraph 69 of schedule 26 to EASR, i.e. the anaerobic digestion of non-waste feedstocks in plant with a capacity exceeding 100 tonnes per day.
 
Activities which this call for evidence does NOT apply to: Anaerobic digestion of waste feedstocks (including manures and slurries) or anaerobic digestion of non-waste feedstocks in plant with a capacity less than 100 tonnes per day. 
General: This spreadsheet is being used to gather information in order to assist SEPA develop permit conditions for non-waste anaerobic digestion activities.

The spreadsheet reproduces the contents of the Waste Treatment BATc document and asks Operators to provide a response against each of the relevant BATc statements.  Further information on which parts to complete is provided below.

Operators are asked to provide as much information as they have.

Where a site is not compliant at the moment, but will be in the future, please indicate the steps to be taken, and the proposed timescale for compliance in your response.
Documentation: Where a  response is too large for direct inclusion on the spreadsheet, a reference should be provided to any separate documents submitted. All documents submitted must include the Permit number and installation name in the header. 
   
Category of Question: What we require:
Narrative/Descriptive BAT For each narrative/descriptive BAT, please complete each Green Box relevant to your installation.

In relation to Compliance Status please select the statement most relevant to your installation from the Drop Down List provided.

You must confirm how your operations meet each technique specified.

If you have a number of different plants on site you must specify which techniques each plant will operate to. 
BAT AELs For each emission point, confirm which AELs you consider applicable and whether you will meet them, both in terms of current emission rate and sampling programme.

Provide supporting emission data where appropriate e.g. where it is a pollutant subject to periodic monitoring and/ or no changes are necessary to meet the new BAT-AEL.

Where data requires to be provided it should be representative of the last 3  years of data where available.
BAT-AELs have been set for:

- Direct discharges to a receiving water body (selected substances/parameters for selected activities)
- Channelled NH3 & odour emissions to air from the biological treatment of waste.

BAT-AELs are presented as a range. Operators should state their performance against that range.
   
What parts to complete:

[Please complete all Green Boxes relevant to your installation.]
BAT 1 to BAT 24  Apply to all sites.
Operators must consider the conclusion and the description and indicate the compliance status of their activity. 
BAT 7  There is a separate spreadsheet to record the monitoring of emissions to water.
All operators must indicate which monitoring applies and how often it is carried out.
BAT 8 There is a separate spreadsheet to record the monitoring of emissions to air.
All operators must indicate which monitoring applies and how often it is carried out.
BAT 20 direct This is a separate spreadsheet to record direct emissions to water.
All operators must indicate which parameter applies and performance against the range.
BAT 20 indirect N/A
Subsequent BAT conclusions are split into three main types of activity. Operators must provide information on all BAT conclusions that apply to their activity. 
BAT 33 to 38  Applies to biological treatment of waste.

This includes aerobic, anaerobic and MBT processes.

Description of Techniques

6.1 Channelled Emissions to Air
Technique Typical pollutant(s) abated Description
Adsorption Mercury, volatile organic compounds, hydrogen sulphide,
odorous compounds
Adsorption is a heterogeneous reaction in which gas molecules are retained on a solid or liquid surface that prefers specific compounds to others and thus removes them from effluent streams. When the surface has adsorbed as much as it can, the adsorbent is replaced or the adsorbed content is desorbed as part of the regeneration of the adsorbent. When desorbed, the contaminants are usually at a higher concentration and can either be recovered or disposed of. The most common adsorbent is granular activated carbon. 
Biofilter Ammonia, hydrogen sulphide, volatile organic compounds, odorous compounds The waste gas stream is passed through a bed of organic material (such as peat, heather, compost, root, tree bark, softwood and different combinations) or some inert material (such as clay, activated carbon, and polyurethane), where it is biologically oxidised by naturally occurring microorganisms into carbon dioxide, water, inorganic salts and biomass.
A biofilter is designed considering the type(s) of waste input. An appropriate bed material, e.g. in terms of water retention capacity, bulk density, porosity, structural integrity, is selected. Also important are an appropriate height and surface area of the filter bed. The biofilter is connected to a suitable ventilation and air circulation system in order to ensure a uniform air distribution through the bed and a sufficient residence time of the waste gas inside the bed.
Condensation and cryogenic condensation Volatile organic compounds  Condensation is a technique that eliminates solvent vapours from a waste gas stream by reducing its temperature below its dew point. For cryogenic condensation, the operating temperature can be down to – 120 °C, but in practice it is often between – 40 °C and – 80 °C in the condensation device. Cryogenic condensation can cope with all VOCs and volatile inorganic pollutants, irrespective of their individual vapour pressures. The low temperatures applied allow for very high condensation efficiencies which make it well-suited as a final VOC emission control technique
Cyclone Dust Cyclone filters are used to remove heavier particulates, which ‘fall out’ as the waste gases are forced into a rotating motion before they leave the separator.
Cyclones are used to control particulate material, primarily PM10. 
Electrostatic percipitator (ESP) Dust Electrostatic precipitators operate such that particles are charged and separated under the influence of an electrical field. Electrostatic precipitators are capable of operating under a wide range of conditions. In a dry ESP, the collected material is mechanically removed (e.g. by shaking, vibration, compressed air), while in a wet ESP it is flushed with a suitable liquid, usually water.
Fabric Filter Dust Fabric filters, often referred to as bag filters, are constructed from porous woven or felted fabric through which gases are passed to remove particles. The use of a fabric filter requires the selection of a fabric suitable for the characteristics of the waste gas and the maximum operating temperature.
HEPA Filter Dust HEPA filters (high-efficiency particle air filters) are absolute filters. The filter medium consists of paper or matted glass fibre with a high packing density. The waste gas stream is passed through the filter medium, where particulate matter is collected.
Thermal oxidation Volatile organic compounds  The oxidation of combustible gases and odorants in a waste gas stream by heating the mixture of contaminants with air or oxygen to above its auto-ignition point in a combustion chamber and maintaining it at a high temperature long enough to complete its combustion to carbon dioxide and water.
Wet scrubbing Dust, volatile organic compounds, gaseous acidic compounds (alkaline scrubber), gaseous alkaline compounds (acid scrubber)  The removal of gaseous or particulate pollutants from a gas stream via mass transfer to a liquid solvent, often water or an aqueous solution. It may involve a chemical reaction (e.g. in an acid or alkaline scrubber). In some cases, the compounds may be recovered from the solvent.
6.2 Diffuse emissions of organic compounds to air
Leak detection and repair (LDAR) programme Volatile organic compounds A structured approach to reduce fugitive emissions of organic compounds by detection and subsequent repair or replacement of leaking components. Currently, sniffing (described by EN 15446) and optical gas imaging methods are available for the identification of leaks.
Sniffing method:
The first step is the detection using hand-held organic compound analysers measuring the concentration adjacent to the equipment (e.g. using flame ionisation or photoionisation). The second step consists of enclosing the component in an impermeable bag to carry out a direct measurement at the source of the emission. This second step is sometimes replaced by mathematical correlation curves derived from statistical results obtained from a large number of previous measurements made on similar components.
Optical gas imaging methods:
Optical imaging uses small lightweight hand-held cameras which enable the visualisation of gas leaks in real time, so that they appear as ‘smoke’ on a video recorder together with the normal image of the component concerned, to easily and rapidly locate significant organic compound leaks. Active systems produce an image with a backscattered infrared laser light reflected on the component and its surroundings. Passive systems are based on the natural infrared radiation of the equipment and its surroundings. 
Measurement of diffuse VOC emissions Volatile organic compounds Sniffing and optical gas imaging methods are described under leak detection and repair programme. Full screening and quantification of emissions from the installation can be undertaken with an appropriate combination of complementary methods, e.g. Solar occultation flux (SOF) or Differential absorption LIDAR (DIAL) campaigns. These results can be used for trend evaluation over time, cross-checking and updating/validation of the ongoing LDAR programme.
Solar occultation flux (SOF):
 The technique is based on the recording and spectrometric Fourier Transform analysis of a broadband infrared or ultraviolet/visible sunlight spectrum along a given geographical itinerary, crossing the wind direction and cutting through VOC plumes.
Differential absorption LIDAR (DIAL):
This is a laser-based technique using differential absorption LIDAR (light detection and ranging), which is the optical analogue of radio wave-based RADAR. The technique relies on the backscattering of laser beam pulses by atmospheric aerosols, and the analysis of the spectral properties of the returned light collected with a telescope. 
6.3 Emissions to water
Activated sludge process Biodegradable organic compound The biological oxidation of dissolved organic pollutants with oxygen using the metabolism of microorganisms. In the presence of dissolved oxygen (injected as air or pure oxygen), the organic components are transformed into carbon dioxide, water or other metabolites and biomass (i.e. the activated sludge). The microorganisms are maintained in suspension in the waste water and the whole mixture is mechanically aerated. The activated sludge mixture is sent to a separation facility from where the sludge is recycled to the aeration tank.
Adsorption Adsorbable dissolved non-biodegradable or inhibitory pollutants, e.g. hydrocarbons, mercury, AOX Separation method in which compounds (i.e. pollutants) in a fluid (i.e. waste water) are retained on a solid surface (typically activated carbon). 
Chemical oxidation Oxidisable dissolved non-biodegradable or inhibitory pollutants, e.g. nitrite, cyanide. Organic compounds are oxidised to less harmful and more easily biodegradable compounds. Techniques include wet oxidation or oxidation with ozone or hydrogen peroxide, optionally supported by catalysts or UV radiation. Chemical oxidation is also used to degrade organic compounds causing odour, taste and colour and for disinfection purposes.
Chemical reduction Reducible dissolved non-biodegradable or inhibitory pollutants, e.g. hexavalent chromium (Cr(VI)) Chemical reduction is the conversion of pollutants by chemical reducing agents into similar but less harmful or hazardous compounds.
Coagulation and flocculation Suspended solids and particulate-bound metals. Coagulation and flocculation are used to separate suspended solids from waste water and are often carried out in successive steps. Coagulation is carried out by adding coagulants with charges opposite to those of the suspended solids. Flocculation is carried out by adding polymers, so that collisions of microfloc particles cause them to bond to produce larger flocs. The flocs formed are subsequently separated by sedimentation, air flotation or filtration. 
Distillation/rectifcation Dissolved non-biodegradable or inhibitory pollutants that can be distilled, e.g. some solvents  Distillation is a technique to separate compounds with different boiling points by partial evaporation and recondensation.
Waste water distillation is the removal of lowboiling contaminants from waste water by transferring them into the vapour phase. Distillation is carried out in columns, equipped with plates or packing material, and a downstream condenser
Equalisation All pollutants  Balancing of flows and pollutant loads by using tanks or other management techniques. 
Evaporation Soluble pollutants  The use of distillation (see above) to concentrate aqueous solutions of high-boiling substances for further use, processing or disposal (e.g. waste water incineration) by transferring water to the vapour phase. It is typically carried out in multistage units with increasing vacuum, to reduce the energy demand. The water vapours are condensed, to be reused or discharged as waste water.
Filtration Suspended solids and particulate-bound metals  The separation of solids from waste water by passing them through a porous medium, e.g. sand filtration, microfiltration and ultrafiltration.
Flotation The separation of solid or liquid particles from waste water by attaching them to fine gas bubbles, usually air. The buoyant particles accumulate at the water surface and are collected with skimmers. 
Ion exchange Ionic dissolved non-biodegradable or inhibitory pollutants, e.g. metals The retention of undesired or hazardous ionic constituents of waste water and their replacement by more acceptable ions using an ion exchange resin. The pollutants are temporarily retained and afterwards released into a regeneration or backwashing liquid.
Membrane bioreactor  Biodegradable organic compounds A combination of activated sludge treatment and membrane filtration. Two variants are used:
a) an external recirculation loop between the activated sludge tank and the membrane module; and b) immersion of the membrane module in the aerated activated sludge tank, where the effluent is filtered through a hollow fibre membrane, the biomass remaining in the tank
Membrance filtration Suspended solids and particulate-bound metals Microfiltration (MF) and ultrafiltration (UF) are membrane filtration processes that retain and concentrate, on one side of the membrane, pollutants such as suspended particles and colloidal particles contained in waste waters.
Neutralisation Acids, alkalis  The adjustment of the pH of waste water to a neutral level (approximately 7) by the addition of chemicals. Sodium hydroxide (NaOH) or calcium hydroxide (Ca(OH)2) may be used to increase the pH, whereas sulphuric acid (H2SO4), hydrochloric acid (HCl) or carbon dioxide (CO2) may be used to decrease the pH. The precipitation of some pollutants may occur during neutralisation
Nitrification/denitirifcation Total nitrogen, ammonia A two-step process that is typically incorporated into biological waste water treatment plants. The first step is aerobic nitrification where micro-organisms oxidise ammonium (NH4+) to the intermediate nitrite (NO2-), which is then further oxidised to nitrate (NO3-). In the subsequent anoxic denitrification step, microorganisms chemically reduce nitrate to nitrogen gas.
Oil-water seperation Oil/grease The separation of oil and water and subsequent oil removal by gravity separation of free oil, using separation equipment or emulsion breaking (using emulsion breaking chemicals such as metal salts, mineral acids, adsorbents and organic polymers).
Sedimentation Suspended solids and particulate-bound metals. The separation of suspended particles by gravitational settling.
Precipitation Precipitable dissolved non-biodegradable or inhibitory pollutants, e.g. metals, phosphorus The conversion of dissolved pollutants into insoluble compounds by adding precipitants. The solid precipitates formed are subsequently separated by sedimentation, air flotation or filtration.
Stripping Purgeable pollutants, e.g. hydrogen sulphide (H2S), ammonia (NH3), some adsorbable organically bound halogens
(AOX), hydrocarbons 
The removal of purgeable pollutants from the aqueous phase by a gaseous phase (e.g. steam, nitrogen or air) that is passed through the liquid. They are subsequently recovered (e.g. by condensation) for further use or disposal. The removal efficiency may be enhanced by increasing the temperature or reducing the pressure. 
6.4 Sorting
Air classifcation   Air classification (or air separation, or aeraulic separation) is a process of approximate sizing of dry mixtures of different particle sizes into groups or grades at cut points ranging from 10 mesh to sub-mesh sizes.  Air classifiers (also called windsifters) complement screens in applications requiring cut points below commercial screen sizes, and supplement sieves and screens for coarser cuts where the special advantages of air classification warrant it.
All-metal seperator   Metals (ferrous and non-ferrous) are sorted by means of a detection coil, in which the magnetic field is influenced by metal particles, linked to a processor that controls the air jet for ejecting the materials that have been detected. 
Electromagmnetic seperation of non-ferrous metals   Non-ferrous metals are sorted by means of eddy current separators. An eddy current is induced by a series of rare earth magnetic or ceramic rotors at the head of a conveyor that spins at high speed independently of the conveyor. This process induces temporary magnetic forces in non-magnetic metals of the same polarity as the rotor, causing the metals to be repelled away and then separated from the other feedstock. 
Mannual seperation   Material is manually separated by means of visual examination by staff on a picking line or on the floor, either to selectively remove a target material from a general waste stream or to remove contamination from an output stream to increase purity. This technique generally targets recyclables (glass, plastic, etc.) and any contaminants, hazardous materials and oversized materials such as WEEE.
Magnetic seperation   Ferrous metals are sorted by means of a magnet which attracts ferrous metal materials. This can be carried out, for example, by an overband magnetic separator or a magnetic drum. 
Near-infrared spectroscopy (NIRS)   Materials are sorted by means of a near-infrared sensor which scans the whole width of the belt conveyor and transmits the characteristic spectra of the different materials to a data processor which controls an air jet for ejecting the materials that have been detected. Generally NIRS is not suitable for sorting black materials.
Sink float tanks   Solid materials are separated into two flows by exploiting the different material densities. 
Size seperation   Materials are sorted according to their particle size. This can be carried out by drum screens, linear and circular oscillating screens, flip-flop screens, flat screens, tumbler screens and moving grates. 
Vibration table   Materials are separated according to their density and size, moving (in slurry in the case of wet tables or wet density separators) across an inclined table, which oscillates backwards and forwards.
X-ray systems   Material composites are sorted according to various material densities, halogen components, or organic components, with the aid of X-rays. The characteristics of the different materials are transmitted to a data processor which controls an air jet for ejecting the materials that have been detected. 
6.5 Management techniques
Accident Management Plan   The accident management plan is part of the EMS (see BAT 1) and identifies hazards posed by the plant and the associated risks and defines measures to address these risks. It considers the inventory of pollutants present or likely to be present which could have environmental consequences if they escape.
Residues Management Plan   A residues management plan is part of the EMS (see BAT 1) and is a set of measures aiming to (1) minimise the generation of residues arising from the treatment of waste; (2) optimise the reuse, regeneration, recycling and/or recovery of energy of the residues, and (3) ensure the proper disposal of residues.

Waste Treatment BAT Conclusions (BATc’s) applicable to Non-Waste AD

Overall environmental performance 

BAT 1 

Implement and adhere to environmental management system (EMS) 

Applicable - links to other BATc’s 

BAT 2 

Techniques relating to waste receipt, segregation, storage etc 

Applicable – the term ‘waste’ here is directly interchangeable with ‘non-waste’ feedstock 

BAT 3 

Waste water and waste gas characterisation and inventory 

Applicable – (i) relates to inputs to the process (swap term ‘waste’ for ‘non-waste’). (ii)&(iii) relate to all water and air emissions from the process, including from effluent treatment plants 

BAT 4 

Waste received storage arrangements 

Applicable – relates to feedstock received rather than ‘waste’ 

BAT 5 

Waste received handling and transfer arrangements 

Applicable – relates to feedstock received rather than ‘waste’ 

BAT 6 

Monitoring of wastewater emissions - key parameters 

Applicable – relates to water emissions identified by BAT3 

BAT 7 

Monitoring of direct emissions to water (i.e. wastewater) – frequency and standards 

Applicable – Only for ‘all waste treatment’ and ‘biological treatment’ processes (i.e. chemical oxygen demand or total organic carbon, total nitrogen, total phosphorus & total suspended solids) 

BAT 8  

Monitoring of channelled emissions to air – frequency and standards 

Applicable – Only for ‘biological treatment’ processes (i.e. hydrogen sulphide, ammonia, odour concentration) 

BAT 9 

 

Not applicable to non-waste AD 

BAT 10 

Monitoring odour emissions 

Applicable 

BAT 11 

Resource utilisation monitoring 

Applicable 

Emissions to Air 

BAT 12 

Odour Management Plan (OMP) 

Applicable – all non-waste AD sites will require to set up and implement an OMP 

BAT 13 

Odour emissions prevention/reduction/controls 

The specific measures listed are not applicable to non-waste AD however you must still demonstrate the overarching aim of preventing odour emissions 

BAT 14 

Diffuse emissions to air prevention/reduction/control 

Applicable – This relates to fugitive, non-channelled emissions. Any technique referencing ‘waste’ handling will also be applicable to handling non-waste feedstock. 

BAT 15 

Flaring controls and minimisation 

Applicable 

BAT 16 

Reducing emissions from flaring 

Applicable 

Noise and Vibration 

BAT 17 

Noise and Vibration Management Plan (NVMP) 

Applicable 

BAT 18 

Noise emissions prevention/reduction/control 

Applicable 

Emissions to Water 

BAT 19 

Optimise water use, reduce wastewater and prevent/reduce emissions to soil and water 

Applicable – BAT 19 c&d (impermeable surfaces and secondary containment measures) are particularly relevant. 

BAT 20 

Treat wastewater to reduce emissions. This includes a table setting out the emission limits you must achieve. 

Applicable – Only for direct discharges from ‘all waste treatments’ and ‘biological treatment’ processes (i.e. chemical oxygen demand or total organic carbon, total nitrogen, total phosphorus & total suspended solids). Appropriate treatment to comply with the emission limits in tables 6.1 must be in place. Table 6.2 for indirect emissions to water is not applicable. 

Emission from accidents and incidents 

BAT 21 

Incident prevention and management controls 

Applicable 

Material efficiency 

BAT 22 

Use of material efficiently by substituting materials with waste 

The specific measures listed are not applicable to non-waste AD however you must still demonstrate the overarching aim of using resources efficiently. 

Energy Efficiency 

BAT 23 

Energy use controls 

Applicable – where waste treatment is referenced, this should be regarded as non-waste treatment 

Reuse of packaging 

BAT 24 

Reuse of packaging to reduce waste 

Limited applicability – relates mainly to incoming feedstock packaging. 

BAT 25-32 

 

Not applicable to non-waste AD 

BAT Conclusions for the Biological Treatment of Waste 

BAT 33 

Selecting inputs for optimal system performance and reduction of odour 

Applicable - the term ‘waste’ here is directly interchangeable with ‘non-waste’ feedstock 

BAT 34 

Using appropriate treatment to reduce channelled emissions to air. This includes a table setting out the emission limits you must achieve 

Applicable – appropriate abatement techniques must be in place to achieve the emission limits in table 6.7 (only the limits for ‘all biological treatment of waste’ is relevant) 

BAT 35 

Reducing wastewater generation and water usage 

Applicable. 

BAT 36 & 37 

 

Not applicable to non-waste AD 

BAT Conclusions for the Biological Treatment of Waste 

BAT 38 

Monitor key process parameters to optimise environmental performance 

Applicable - the term ‘waste’ here is directly interchangeable with ‘non-waste’ feedstock 

BAT 39-53 

 

Not applicable to non-waste AD 

 

 

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