Comments from the BBF board on the Environment Agency Regulation Position Statement.

Comments on the Environment Agency Regulation Position Statement:  Manufacture and Use of Biochar from Specified Waste

We welcome the publication of the draft RPS by the Environment Agency.  Our comments are below.

  1. Definition of biochar.  We would prefer that the definition does not include the word ‘pyrolysis.  It is possible that biochar can be produced by other technologies such as gasification. We therefore prefer to use the definition:  ‘Biochar is a solid material obtained from thermochemical conversion of biomass in an oxygen-limited environment that is used for the safe and long-term storage of carbon in the environment and for soil improvement’
  2. Under ‘Manufacture of Biochar from Specified Wastes’ (point 4) and ‘Use of Waste Derived Biochar’ (point 2), we would like the RPS to include the waste code 19.09.02 for biochar to be applied to land. This is a clean charcoal (spent activated carbon) waste that has been used for filtering water and could be a useful material as biochar. At present this material is either being landfilled or burnt as a fuel.
  3. Under ‘Use of Waste Derived Biochar’ (point 1), it may be worth mentioning that a further benefit of biochar spreading is to store carbon over climate-change relevant time periods.  We also wonder whether it may be better to use the term ‘soil organic matter’ rather than biomass at the end of the line (assuming we can call biochar a type of SOM).
  4. Under ‘Use of Waste Derived Biochar’.  Point (3). We are unclear why it is proposed to limit the application rate to a maximum of 1 tonne per hectare in any 12 month period. To us, this seems unnecessarily restrictive and we would prefer a risk-based procedure for calculating maximum application rates.  1 tonne of biochar incorporated in a soil to a depth of 23cm represents only c. 0.25% to 0.33% of the soil mass (depending on bulk density of the receiving soil). Therefore we would suggest that the application rate methodology used in the Biochar Quality Mandate (BQM), Section 7 and Appendix E, might be a good reference for this RPS as it is based upon an already tried-and-tested application methodology for sewage sludge application that is in place and used by the regulators today.
  5. Under ‘Use of Waste Derived Biochar’.  Point (4). We are unclear why there is a limit of 10 tonnes of waste stored at the site at any one time. If the storage site is controlled and managed appropriately, is there any reason per se why 10 tonnes is the maximum?
  6. Typographical

a)      2nd paragraph down under ‘Background’ should read, ‘physico-chemical properties’ (not ‘physio-chemical properties’).

b)      3rd paragraph down under ‘Background’ should read ‘manufacture of biochar’ (not ‘manufacture or biochar’).