IrBEA submits comments uring support for biogas/biomethane and biomass

In Ireland, Irish Bioenergy Association (IrBEA) submitted proposals for the recently closed public consultation on the review of exempted development on behalf of its members for both biogas/biomethane and biomass developments that should be included in the exempted development regulation changes being considered by the Government. 

IrBEA calls for the following:

·      That any new exempted slurry storage infrastructure must also provide for facilities for the on-farm storage of digestate from anaerobic digestion processes.

·      The proposed 1000 cubic metres size for storage should be increased to 2500 cubic metres. This size would provide a buffer against unsuitable weather conditions for manure and digestate spreading and allows for optimised use during the growing season when plants are best placed to uptake and avail of the nutrients, thus maximising the positive impact on the environment and water quality from land spreading.

·      All storage tanks should be covered as this will reduce emissions to air, eliminate rainwater ingress thus improving the nutrient content of the stored material.

·      Farms with additional storage will be obvious partners for local biogas/biomethane plants. Tillage farms should not be excluded from this exemption as they need to import organic manures and often have no associated livestock buildings that would qualify under the exemption, as currently drafted.

·      Farm biogas facilities which meet the requirements of Department of Agriculture, Food and the Marine (DAFM) Animal by Products (ABP) Regulation Type 9 Plants should be exempted development.

Also, larger farm biogas plants that use materials/feedstock that are currently eligible to be land spread on farmland should also be exempted development.

The 200 square metre threshold, currently exempted and outlined in class 8 (exempted development rural), should be increased from the current 200 square metres to 1000 square metres for silage areas specifically. This increase would be important to facilitate the development of silage storage facilities on farms where the silage would be used as a feedstock for biomethane production and supply to a production facility.

A contradiction in the current exemptions must be addressed where, Class 8  currently exempts the installation of animal feed silos by farmers for storage of animal feed up to a height of 8 metres, subject to conditions. Whereas Class 18E3 (exempted development rural – renewable technologies on farms) states that the maximum height for an identical silo to be used as a store for wood pellets or wood chip, for fuelling a biomass heating system on the same farm, should not exceed 3 metres. Biomass storage on farms should also be allowable up to 8 metres.

Exemption should extend to all containerised biomass fuelled heating systems for the provision of heat at education facilities / schools.

Regarding the health exemptions, the reference to renewable energy technologies to support self-generation of power should be extended to include renewable energy technologies (including biomass / biogas) to support the production of renewable heat for use on the medical site.