Landspreading: produce a benefit statement - Supply Chain Council of European Union

When you apply to deploy mobile plant to landspread waste you must produce a benefit statement. You must be able to demonstrate waste recovery without causing harm.

Use this guidance, which includes a worked example, and the benefit statement template for what to include.

The completed example and template set out the type of information we need to make our assessment. You may need to provide further site-specific information where applicable.

This guidance and the completed example follow the same layout and order as the template.

You must also make sure that you comply with the requirements of your permit.

Include the benefit statement with your Landspreading: form LPD1 application for deployment.

Section 1. Qualifications and technical expertise

To produce a benefit statement you must be an appropriate technical expert. This means you must have relevant:

qualifications
experience
membership

For example, you can use a fertiliser advisers certification and training scheme (FACTS) qualified adviser to make sure you meet the required standards. This is the preferred qualification for assessing agricultural benefit.

For ecological improvement, we do not have a preferred qualification. However, we expect a person with relevant qualifications, experience or professional membership to prepare the benefit statement.

Section 2. Waste recovery without harm

Your landspreading permit only allows waste recovery activities. They must result in agricultural benefit or ecological improvement.

You must be able to confirm how the activity:

meets the 5 waste recovery tests
provides agricultural benefit or ecological improvement
meets the requirements of your permit and deployment

Your permit does not allow waste disposal activities.

Meet the 5 waste recovery tests

Waste recovery means using waste to replace other non-waste materials to achieve a beneficial use in a way that does not result in harm. It is where a material that would otherwise be disposed of can be used instead of a non-waste material.

You must show that the activity meets all these waste recovery tests.

There must be a clear benefit.
The waste is suitable for use.
The minimum amount of waste is being used for the intended benefit.
The waste is a substitute for non-waste material.
The waste is recovered to an appropriate standard meeting the requirements of your permit and deployment.

We use the same tests to assess if your activity is waste recovery.

Test 1 – clear benefit

We will consider the scale of the operation in relation to the level of benefit that is achieved. For example, if the deployment uses:

a relatively small amount of waste to achieve a measurable benefit, we are likely to class it as a waste recovery activity
a large amount of waste on land where the benefit is too small to measure, we are likely to class it as a waste disposal activity

Test 2 – suitable for use

The waste stream must be suitable for its intended use without further treatment.

You must describe the agricultural benefit or ecological improvement that the deployment will achieve.

Your activities must not cause harm. If the activities pose a risk to human health, animal health or the environment we are unlikely to class it as a waste recovery activity.

Test 3 – minimum amount of waste for intended benefit

The application rate or the quantity of waste used must be no more than is needed to give the intended benefit or improvement. For example, to meet crop requirements.

Applying more waste than is required is classed as waste disposal unless you can provide justification.

For deployments involving land restoration under SR2010 No 5 or a similar bespoke permit, you must justify the quantity of waste intended for use. Provide plans and diagrams that clearly show the scale of the project and the intended final ground levels.

You must not use your landspreading permit for the sole purpose of levelling or raising the land. This fails the waste recovery tests and we will class it as disposal by landfill. For more information see the Levelling the land section in this document.

Test 4 – substitute for non-waste material

You must show that the waste intended for use is a substitute for a non-waste material. It must be used in the same way as the non-waste it is replacing. For example, to replace or supplement a manufactured fertiliser. This means applying it at a time when the crop can use it and in amounts that the crop can take up.

You must not spread:

solid wastes that smother crops
liquid wastes that cause scorch
oily wastes that coat the crop or soil particles – see manage oil and fat trap wastes in Landspreading: how to manage soil health

We class these activities as disposal, not recovery.

Spreading waste streams at inappropriate times, under inappropriate conditions or at excessive rates is likely to fail this waste recovery test.

Large industrial processes and waste management processes can rely on landspreading as a major outlet for their waste streams. However, these processes do not always produce waste at the appropriate time to landspread it. In these cases you may:

identify suitable waste storage arrangements to store the waste until the time is right to spread it
only use the amount of waste that is required to achieve the defined benefit

Test 5 – operate to an appropriate standard

This means you must keep to the requirements of your permit and agreed deployment. If you do not, we will determine your deployment as waste disposal and we may take enforcement action.

Further information on waste recovery

For more guidance on waste recovery see waste recovery test and evidence to support recovery of waste in Waste recovery plans and deposit for recovery permits.

The effects of spreading physical contaminants

We will usually class deliberate landspreading of physical contaminants as a waste disposal operation. The operation would fail the waste recovery tests and would not give benefit to soil. Physical contaminants can:

adversely affect the countryside or places of special interest either directly or at a distance, such as from wind-blown litter
be taken up by grain harvesting and grass cutting, including by silage making machinery and the resulting silage
cause a disbenefit, for example, resulting in extra cleaning requirements for low depth root crops such as potatoes, cabbage and cauliflower
be picked up by grazing livestock and other animals, including pets

Do not accept any waste that requires treatment or sorting.

Using soil substitutes or conditioners and improvers

When proposing to use a soil substitute or soil conditioner or improver you must know how they differ:

You can use waste code 19 12 12 Soil substitutes other than that containing dangerous substances only as a soil substitute. You can use it for ecological improvement in land restoration and reclamation schemes under SR2010 No 5 or a similar bespoke permit. For example, it can be used in landfill restoration schemes to create a vegetated area where there is no existing soil profile. You must be able to demonstrate ecological improvement. Where a soil profile already exists, you must not use 19 12 12. You can use many other types of waste as soil conditioners or improvers as listed in your permit.

We accept that to create a complete soil substitute, wastes may need to be blended with other imported soil substitutes. The resultant soil needs to be created to an appropriate standard, usually the British Standard specification for topsoil. It must also meet the requirements for potentially toxic elements (PTEs) as given in the Sewage sludge in agriculture: code of practice.

To produce soil substitutes, you will need to hold SR2010 No 12: treatment of waste to produce soil, soil substitutes and aggregate or a bespoke permit.

The soil substitute must not include:

hazardous waste or dangerous substances
contaminants such as asbestos fragments, plastics, glass, metals, treated timber, foils and films

Levelling the land

Under SR2010 No 5 levelling the land can provide agricultural benefit or ecological improvement. You must demonstrate how your deployment will meet all 5 waste recovery tests, in particular test 3.

We may consider the following examples as waste recovery activities:

bringing unusable areas of a field into production
improving drainage
improving the landform to reduce erosion and run-off
protecting buried services
filling or repairing gullies or other areas affected by soil erosion

Normally, spreading means applying an even, shallow layer of waste and then incorporating it into the soil profile (rooting zone) using standard agricultural operations, such as ploughing.

For example, for waste types limited to 250 tonnes for each hectare (t/ha), spreading the waste evenly equates to a waste depth of approximately 2.5cm (assuming a waste density of 1 tonne for each cubic metre (t/m³)). Similarly, for wastes limited to 1,500t/ha, this would be a depth of 15cm.

You can spread specific waste types under SR2010 No 4 and No 5 at rates up to 5,000t/ha. This equates to a waste depth of approximately 50cm and would allow land levelling. See the R10 limits of activities in the permit for details of these wastes.

It may be possible to spread waste at greater depths over a small area of land. For example, to ‘spot’ treat a small area of a field affected by erosion.

Meet the criteria for agricultural benefit or ecological improvement

Your benefit statement must show how your deployment will result in agricultural benefit or ecological improvement without causing harm. If you use different criteria to justify benefit or ecological improvement to agricultural or non-agricultural land you must:

provide robust scientific evidence
use appropriate technical expertise

Criteria for assessing agricultural benefit

Agricultural benefit is the physical, chemical or biological improvement of soil. It must provide, maintain or improve the ability of the soil as a growing medium.

Your deployment can also give benefit to help industrial crops grow, such as timber for biomass.

You can assess agricultural benefit for soil improvement against one or more of these criteria:

crop nutrient requirements, such as, nitrogen, phosphorus, potassium – the timing and amount to be applied
soil chemical properties, such as, liming and pH
soil physical properties, such as organic matter content and structure
soil water content
levelling the land, if applicable, however you must not use your landspreading permit for the sole purpose of levelling or raising the land

To set crop nutrient levels we recommend you use Nutrient Management Guide (RB209). If you want to deviate from the recommendations, see Section 6. Soil and crop requirements in this guide.

We will use these criteria to assess if the proposed waste application will provide agricultural benefit.

Criteria for assessing ecological improvement

Ecological improvement can provide, maintain or improve the ability of the soil as a growing medium for non-agricultural use.

You can assess ecological improvement against one or more of these criteria:

develop, maintain or improve existing habitats to give greater biodiversity or sustainability
provide new habitats
prevent the deterioration of habitats
develop, maintain or improve landscapes, amenity or recreation sites

We will use these criteria to assess if the proposed waste application will provide ecological improvement.

Ecological improvement: reclamation of derelict or degraded land

You can use SR2010 No 5 or a similar bespoke permit for reclaiming, restoring or improving land. You can reclaim derelict or degraded land such as mineral extraction or waste management facilities. The land must have no existing conservation value and not be a specialised habitat.

You can assess against the same criteria given for agricultural benefit. This means the physical, chemical and biological enhancement of the soil to create or support a habitat.

The activity must not damage existing habitats.

To create a habitat, we advise you to consult the appropriate conservation agency.

Section 3. Waste type

The waste type must be listed in the permit.

Refer to Landspreading: benefits and risks of the waste types you can use for details of the acceptable waste types, their benefits and risks and other sources of information.

Section 4. Waste storage and spreading

You need to provide details of waste storage and spreading in your benefit statement.

Section 5. Operational details

You will need to consider any benefits and risks from your storage method and spreading techniques. See Landspreading: how to comply with your permit for the benefits and risks of different types of:

storage – under section 2.1.1 R13 storing waste before you spread
spreading techniques – under 2.1.1 R10 land treatment resulting in benefit to agriculture or ecological improvement

Provide information on your proposed operations. For example, where applicable, how you will use the waste:

on crops to replace use of manufactured fertilisers
as a soil substitute in a land restoration scheme
for other reasons, such as levelling the land

If you plan to use liquid wastes, tell us if there:

is any mole draining or sub-soiling planned
are any land drains in the field, especially where wastes are injected and how you will address spreading in dry weather when the ground may have cracked

Provide details of when and how the waste will be spread. It is not acceptable to state that landspreading operations will take place over 365 days according to crop requirement. A time period such as July or August is acceptable.

Application rates for mixed waste streams

You cannot demonstrate benefit from a mixed waste stream. You are allowed up to 10 waste streams for one deployment. Each waste stream must give benefit to the receiving land at the proposed spreading rate.

You can only mix waste streams together for ease of handling. Tell us about any risks that may result from mixing the waste. This includes the risks of mixing with other wastes listed on a different deployment application for the same area of land.

You must tell us in the benefit statement the proportion of each waste stream in the mix.

The mixed waste cannot exceed the lowest applicable application rate calculated for an individual waste stream.

When applying more than one waste to the same parcel of land you must base the application rate on the proportion of each waste stream. Each waste stream must give measurable benefit.

If you cannot do this, you must use the waste stream with the highest nutrient, PTE or other limiting factor as the maximum application rate. Typically, inclusion of higher risk wastes means spreading at lower application rates.

Details about the crop

Provide these details about the crop:

the current crop, including the projected yield in t/ha if known
if the straw will be removed for cereals, oilseed rape, pulse crops
the next crop
any sensitive crops within the rotation for which you are amending the soil

If the waste is not being used for crops provide details of the land use.

Other relevant information

You may need to provide other relevant information relating to your operations in other sections of the benefit statement.

For example, explain any potential negative impacts to the land, soil or crop in Section 7.

Section 6. Benefits and nutrients supplied to the land, soil, or crop

This is where you tell us what the benefits of the deployment will be.

The information you provide must cover each waste stream being spread to each area of receiving land.

You must base your justification on the waste analysis and receiving soil analysis. You will need to provide the full analytical results with your deployment application.

For how to provide the soil category and description, see identify and describe soil in Landspreading: how to manage soil health.

We expect the deployment to form part of the whole farm nutrient management plan. If your deployment proposes to rectify a deficiency of one essential plant nutrient (at a level recommended by RB209), you must not apply other nutrients unnecessarily.

You can only apply nutrients that the soil and crop needs. Over-applying nutrients fails waste recovery test 3.

Soil and crop requirements

You must show how the waste application will add the nutrients that the crop and soil need. You can provide a table to show the nutrient requirements like Table 1 in the completed example.

We normally expect you to use the RB209 recommendations for setting nutrient levels. They are set at the economic optimum for crop production.

RB209 contains information on recommended rates for nitrogen, phosphorus, potassium, magnesium, sulphur and sodium. You will need to use appropriate expert advice or different guidance to work out how to add and correct deficiencies of other trace elements.

If you do not want to use the RB209 recommendations, you must:

provide appropriate technical justification
make sure the justification is relevant to the waste and to the land it will be spread on
state your information source

For any other method you must:

base it on sound scientific evidence using appropriate technical expertise
make sure it is relevant to land management practices for England
make sure it is tried and tested – we do not accept unpublished, theoretical or laboratory-based experimental data
demonstrate how your deployment will meet the waste recovery tests

If the waste does not supply all the crop requirements, you must account for adding more fertiliser or manure. For how to plan and control nutrient levels see Use of organic manures and manufactured fertilisers on farmland.

Application rates

Application rates quantify the amount of nutrients, PTEs or other contaminants that will be added to the soil. Your permit sets the application rates you can use. You must consider any waste applied under previous deployments to make sure you do not set the rate too high (this is particularly relevant to phosphate addition).

Other soil properties

See Landspreading: how to manage soil health for details on how to manage:

the water content of the soil
the chemical properties of the soil, such as pH and liming
the physical properties of the soil, such as organic matter content and structure
nitrate, ammonia and nitrogen volatilisation, phosphate, potash and magnesium and sulphur
slow release nutrients in restoration schemes

If cover crops form part of the crop rotation, you can use the winter cover crops advice note.

Section 7. Potential negative impacts to the land, soil or crop

Describe any potential negative impacts from the proposed activities and explain how these will be managed. We may ask for more information if the benefit statement does not adequately address any identified potential hazard.

Use the waste and receiving soil analyses to check if the waste stream contains any substances or has any properties that could cause a negative impact to the land, soil or crop. You can provide summaries of the waste and soil analyses in tables, like Tables 2 and 3 in the completed example.

Limits for PTEs

Your deployment should not exceed the PTE limits given in the Sewage sludge use in agriculture: code of practice.

The limits apply to all waste types, not just sludge.

If you are spreading to:

You must not landspread the waste if it will cause the PTE levels to exceed these limits unless you can justify doing so.

For soils in the pH ranges of 5.0 to less than 5.5 and greater than 5.5 to less than 6.0 the permitted concentrations for lead, zinc, copper, nickel and cadmium are provisional. They will be reviewed when current research into their effects on certain crops and livestock is completed.

The accepted safe level of molybdenum in agricultural soils is 4mg/kg. In areas where a higher concentration is found naturally, get advice from an agricultural specialist before you use the waste. This advice will take account of existing molybdenum levels and current arrangements to provide copper supplements to livestock.

You can provide a table like Table 4 in the completed example. It compares the waste and receiving soil analyses with the limits for PTEs and any other contaminants. Include the:

PTE limits as given in the Sewage sludge in agriculture: code of practice
PTE addition from the application of the waste in t/ha (kg/ha)
PTE addition as a percentage of maximum annual rate of addition
estimated concentration in soil after waste application in mg/kg (dry matter)
per cent of maximum permissible concentration in soil after the waste application of the waste

Justify any accumulation of PTEs and other contaminants from the waste and the receiving soil analyses.

For further details on:

pH

The soil’s pH needs to be between 6.0 and 7.0.

A change in the pH of the receiving soil may cause:

the PTEs or other contaminants mobility in the soil to change
a decrease in crop yields
undesirable effects on established plants

For more detail, see manage soil pH in Landspreading: how to manage soil health.

Other contaminants

You must consider any other contaminant in your waste stream. For example, the effects of iodine from animal by-product wastes.

Find details on the benefits and risks from your specific waste in the guidance Landspreading: benefits and risks of the waste types you can use.

You must consider physical contaminants like, plastics and glass that may cause harm.

See Landspreading: how to manage soil health for information on the potential negative impacts to soil from:

sodium and chloride
salty whey and other high conductivity wastes
carbon to nitrogen ratio
nitrate, ammonia and nitrogen-volatilisation
phosphate, potash and magnesium
sulphur
iodine
oil and fat trap wastes

Tell us about the inclusion of any trace elements and any potential negative impact.

You may need to consider background soil concentrations if the waste analysis shows that there are other contaminants present such as iron, manganese and aluminium.

See other contaminants under Manage contaminants in Landspreading: how to manage soil health.

Disbenefit from organic matter to applied agrochemicals

Applying wastes high in organic matter may affect any pesticides, herbicides and other agrochemicals used. This can result in an agricultural disbenefit. See manage soil organic matter and applied agrochemicals under Manage contaminants in Landspreading: how to manage soil health.

Potential negative impacts to land and soil

Provide information on:

how you will meet the limits for PTEs – you may need to give additional justification
other characteristics of the waste such as pH, conductivity, oils and fats, trace elements, salt content, other contaminants
potential for physical contaminants such as, plastics and glass that may pollute the soil

Provide details of other potential negative impact such as:

site topography, slopes and other natural features that affect the operation
impact of the operations on the receiving soil for example, wheel ruts, compaction, structural damage, soil erosion and run-off
how the waste is expected to behave, such as ‘like a slurry’
any other potential negative impacts from the operation, for example, risks from traffic and vandalism

Section 8. List the sensitive receptors

List the sensitive receptors in your benefit statement. The following are examples of sensitive receptors:

habitats and designated areas including European sites, Sites of special scientific interest, local nature reserves
groundwater, including source protection zones
dwellings, schools, business premises
footpaths and other public rights of way
amenity areas
soil
boreholes, wells, springs and private water supplies
surface water
hedge lines and ditches
grazing animals

You will also have to consider nature conservation places and woodland. See:

The controls you use during all stages of your activities can reduce the potential risks to sensitive receptors.

Section 9. Actions to reduce the impacts on identified sensitive receptors

Provide details of what measures will be in place to reduce any impact to the identified sensitive receptors. For example, provide information on:

waste deliveries to the field and how they will be supervised
how spillages will be managed
how the potential for odour will be prevented
use of buffer strips, for example no-spread zones and that machinery will not turn in them
the daily checks on machinery and how you will record these
how the land will be protected from machinery, such as adjusting tyre pressures to match the soil conditions, spreading direction and load
the service schedule of machinery and how the spreading equipment is calibrated
how the potential for run-off will be managed

Consider how the timing of your spreading will impact sensitive receptors. For example:

during the week (Monday to Friday) when any nearby public rights of way and recreational facilities are likely to be used less
at weekends when nearby schools or businesses are likely to be closed
in favourable weather conditions, including how the wind direction will be considered

Include information on how you will protect:

groundwater
sensitive habitats from windblown nutrients or contaminants from inappropriate spreading
animal health

Tell us how you will meet the recommendations given in Protecting our water, soil and air.

Animal health

Over-applying PTEs and other contaminants can be toxic to animals. See effects of some metals and other substances in soils under Manage contaminants in Landspreading: how to manage soil health. This gives an overview of some potential effects from some elements. You may need to use other sources of information. Provide details of this if applicable.

Section 10. Contingency planning

Provide the contingency planning measures for this deployment. Refer to the written management system for the permit.

If, due to an unplanned event, it is not possible to accept the waste at the deployment site, you must contact the waste producer to stop deliveries.

Both the waste producer and the landspreading operator must comply with the waste duty of care. Where for example, extreme weather prevents waste being landspread for extended periods, contingency planning will ensure the waste is managed in an environmentally sound way.

Provide details of circumstances when spreading will not take place or will have to stop. This can be related to the weather or unsuitable ground conditions.

You will also need to plan for and consider for example:

prolonged waste storage – such as beyond the time allowed on your deployment
machinery breakdown, transfer and umbilical pipe failure
staffing problems due to sickness, holiday or other reasons
exceptional circumstances such as prolonged adverse weather – we accept that this may affect the timing of when you can spread

We accept that exceptional circumstances may affect your timing for being able to spread. You must contact us if this is an issue.

Section 11. Compliance with other applicable legislation

Tell us if the receiving land or waste storage location is within a designated nitrate vulnerable zone (NVZ). If it is, provide details of:

the closed periods that apply for the waste type
how the application rates will comply with the crop requirement and field, or whole farm limits
how other organic waste or manure applications are accounted for
justification that NVZ requirements are covered
how the landowners will be given information (to meet the requirements for record keeping)

Confirm that your supply of waste will comply with the requirements of Rules for farmers and land managers to prevent water pollution – the farming rules for water.

Benefit statement completed example

You can use this benefit statement completed example with the benefit statement template for the type of information we expect to see. You may need to provide further site-specific information where applicable.

1. Qualifications and technical expertise

Name:

Employer details:

Professional qualifications: BSc Agriculture.

FACTS registration number:

Experience: I have worked in the agricultural industry for the past 15 years providing agronomy advice on arable cropping and soil management. For the past 5 years I have worked as a consultant for recycling materials to land.

This deployment application relates to permit number:

2. Waste recovery without harm

I can confirm the deployment is a waste recovery activity based on the 5 waste recovery tests and the information I have supplied in this benefit statement.

This deployment will provide agricultural benefit to the soil and crop. It will:

meet the crop nutrient requirements
be beneficial to the physical properties of the soil by providing organic content
improve the soil water content

3. Waste type

Waste producer name and address:

List of waste (LoW) code: 02 02 01 – SR2010 No 4 Table 2.2B List B waste.

Waste description: Untreated washwaters and sludges from washing and cleaning from abattoirs, poultry preparation plants, rendering plants or fish preparation plants only.

Additional information

The waste is untreated washwater sludge. It is from washing slaughterhouse buildings containing animal excrement wastes at:

The sludge is collected from washwater settling in the waste producer’s onsite effluent tank.

The waste is a slurry.

Manure and slurry from abattoirs are category 2 Animal By-Products Regulation (ABPR) material. They are exempt from the requirement of storage in a designated category 2 ABPR plant. Therefore, handling and storing the waste does not need approval.

4. Waste storage and spreading

Main address of the farm or site:

12-digit grid reference of the place of storage:

The quantity to be stored at any one time is 100m³ – this is restricted by the size of the mobile field storage tank.

The total quantity to be spread is 2,000 tonnes.

The area of receiving land is 10ha on a single parcel of land.

The place of storage (temporary tank position) and the spreading area are shown on the location map reference number:

Location map [reference number] shows the sensitive receptors and spreading control areas.

5. Operational details

Storage and spreading

The sealed storage tank will be situated at the top of the field adjacent to the farm access track. This will allow vehicular access without causing unnecessary compaction or rutting to the land. This is shown on the location map [reference number].

Spreading is by umbilical supplied shallow injection. This will place the material in the top 10cm of the soil, reducing volatilisation, nutrient loss and odour.

The spread width is approximately 6m.

Machinery will run on the barley stubble to reduce surface damage and compaction caused by the field operations.

There will be no spreading in the areas identified for sub-soiling on the headlands and heavily trafficked areas. This is to prevent run-off. This is shown on location map [reference number].

When and how the waste will be spread

The waste will be spread after the winter barley is harvested and the barley straw is removed. This is usually in July or August.

Cropping details

Current crop is winter barley with an expected yield of 7.5t/ha.

The barley straw will be removed from the field and sold as feed or bedding straw.

The next crop will be winter oilseed rape.

There are no plans to grow sensitive crops in the next rotation.

Other operational details

Other beneficial operational practices include:

minimal cultivation techniques to sow the winter oilseed rape crop
compacted soil will be broken up by targeted sub-soiling on the headlands and heavily trafficked areas with direct drilling into the stubble
stubble will be left to protect the emerging seedlings from both adverse weather and scavenging birds

6. Benefits and nutrients supplied to the land, soil or crop

The benefitting crop is winter-sown oilseed rape.

The expected crop yield is 3.5t/ha (fresh weight) – seed only.

The soil category is a deep silty soil.

The soil is a silt clay loam texture.

The proposed waste stream application rate is 200t/ha.

The waste stream will provide the following benefits, it will:

meet the crop nutrient requirements as it has moderate levels of nitrogen and smaller amounts of phosphate, potash and sulphur
be beneficial to the soil physical properties by providing organic content – this will help to improve the soil structure and provide micronutrients
improve the soil water content by providing moisture to the soil as the field is on a south facing slope and prone to drying

Table 1 shows the nutrient requirement for winter-sown oilseed rape on a silt clay loam with a SNS of 1. The nutrient requirement for the crop is based on RB209.

Table 1. Nutrient requirements for the crop

Nutrient	SNS or index	Nutrient requirement kg/ha
Nitrogen	SNS 1 seed bed	30
Phosphate	Index 1	80
Potash	Index 2 minus	40
Magnesium	Index 3	0
Sulphur	RB209 recommendation 50 to 75	75

The waste stream will provide these total nutrients:

150 kg/ha of nitrogen
9 kg/ha of phosphate
21 kg/ha of potash
3 kg/ha of magnesium
15 kg/ha of sulphur

The application rate of 200t/ha provides 150kg/ha of nitrogen of which only 20% is readily available to the crop. This provides 30kg/ha of crop available nitrogen in the seed bed for the winter sown oilseed rape.

The waste stream has a total solid content of 2.5%. This will supply 5t/ha of solid material to the soil. It will act in a similar way to the application of farmyard manure, adding an organic conditioner to the soil and as a nutrient reserve. Nutrients held in the solid part will become available to later crops as they are released.

The magnesium index of the soil is 3, which shows that the crop has no additional requirement for it. The waste stream contains minimal quantities of magnesium. This application will supply 3kg magnesium. The projected average crop yield on this farm is 3.2t/ha and average crop off-take is 2.4kg magnesium per tonne. The magnesium supplied in the waste will provide approximately 36% of the crop off-take.

The waste will also provide limited quantities of micronutrients to the soil, including approximately:

0.017 kg/ha of boron
0.035 kg/ha of manganese
0.003 kg/ha of molybdenum
0.016 kg/ha of zinc

The waste has been tested for iodine and less than 0.01 mg/kg was detected.

Nutrients held in the solid part will become available to later crops as they are released.

The field is on a south facing slope and prone to drying. The liquid contained in the waste will help to provide moisture in the soil. The direct drilling will also help preserve soil moisture by minimising soil disturbance providing the seeds with ideal germination conditions.

Additional fertilisers, mainly phosphate and potash fertiliser, will be put in bands when drilling. This will address the shortfall from the waste application.

7. Potential negative impacts to the land, soil or crop

Tables 2 and 3 provide summaries of the waste and receiving soil analyses. The full analytical results are included with the deployment application.

Table 2. Summary of the waste analysis

Determinand	Value
Total solids	2.5 %
Conductivity	401 uS/cm
pH	7.2
Biological oxygen demand	190 mg/l
Total nitrogen	0.075 % w/w
Total carbon	0.065 % w/w
Carbon to nitrogen ratio	0.8:1
Ammonium nitrogen	199 mg/kg
Total phosphorus	16.3 mg/kg
Total potassium	71.0 mg/kg
Total magnesium	6.33 mg/kg
Total copper	<0.01 mg/kg
Total zinc	0.078 mg/kg
Total sulphur	12.0 mg/kg
Total calcium	48.7 mg/kg
Total molybdenum	0.014 mg/kg
Total lead	0.011 mg/kg
Total cadmium	0.012 mg/kg
Total mercury	0.05 mg/kg
Total nickel	0.067 mg/kg
Total chromium	0.173 mg/kg
Total sodium	22.2 mg/kg
Total arsenic	<0.01 mg/kg
Total selenium	0.011 mg/kg
Fluoride	2.70 mg/kg
Iodine	<0.01 mg/kg

Table 3. Summary of the receiving soil analysis

Determinand	Value
Soil pH	6.5
Soil lime requirement	0.00 t/ha
Available phosphorus (index)	14.2 mg/l (index 1)
Available potassium (index)	148 mg/l (index 2-)
Available magnesium (index)	154 mg/l (index 3)
Total copper	14.2 mg/kg
Total zinc	86.1 mg/kg
Total lead	43.9 mg/kg
Total cadmium	0.52 mg/kg
Total nickel	16.4 mg/kg
Total chromium	23.1 mg/kg
Total mercury	0.03 mg/kg

Table 4. Comparison of the waste and receiving soil analyses with the limit values for PTEs

(total) PTE	Maximum permissible concentration of PTE in soil (mg/kg dry solids) (pH 6.5)	Maximum permissible average annual rate of PTE addition over 10-years (kg/ha)	PTE addition from the application of the waste at 200t/ha (kg/ha)	PTE addition as % of maximum annual rate of addition	Estimated concentration in soil after waste application (mg/kg) (dry matter)	Per cent of maximum permissible concentration in soil after waste application
Arsenic	50	0.7	<0.002	0.29%	15.6	31.2%
Cadmium	3	0.15	0.0024	1.60%	0.52	17.3%
Chromium	400	15	0.0346	0.23%	23.1	5.8%
Copper	135	7.5	>0.002	0.03%	14.2	10.5%
Fluoride	500	20	0.54	2.70%	1.5	0.3%
Lead	300	15	0.0022	0.01%	43.9	14.6%
Mercury	1	0.1	0.01	10.0%	0.03	3.0%
Molybdenum	4	0.2	0.0028	1.40%	1.03	25.8%
Nickel	75	3	0.0134	0.45%	16.4	21.9%
Selenium	3	0.15	0.0022	1.47%	1.44	48.0%
Zinc	200	15	0.0156	0.10%	86.1	43.1%

The waste stream contains traces of PTEs.

The receiving soil currently contains PTEs at concentrations of between 0.3% and 48%.

Using the 200t/ha application rate gives little additional PTEs.

The loading is below the maximum permissible average annual rate for all PTE additions over 10 years.

Applying the waste stream will not exceed any of the maximum permissible concentrations of PTEs in soil.

Other characteristics of the waste are as follows:

the pH of the waste is 7.2 and the receiving soil is 6.5 so the application of the waste will not cause harm
the conductivity of the waste is low (401uS/cm) and the level of fats and oils is negligible
other trace elements are estimated to add less than 0.02% to current soil concentrations – this applies to antimony, barium, beryllium, cobalt, silver, thallium, tin and vanadium

Other potential negative impacts

The site slopes at approximately 5 degrees toward the bottom of the valley where a well-established hedge separates the site from the field through which the river flows. As the waste behaves like a slurry, run-off may pose a risk if not addressed. Section 9 explains how risk will be managed.

Machinery will run on stubble, tyres and tyre pressures will be adjusted to match the soil conditions, spreading direction and load.

Odours from spreading the waste may be an issue. On-field storage uses a sealed tank with lockable valves. The lockable valves will help to avoid vandalism. Section 9 explains how odour will be controlled.

8. List the sensitive receptors

The sensitive human receptors are:

2 private dwellings within 400m of the receiving land – the occupants may be exposed to odours from spreading operations
a public right of way which runs east to west along the bank of the river at the south of the receiving land – people using this path may be exposed to odour from spreading and aerosol drift

There are no boreholes, wells, springs or private water supplies within 250m of the waste storage location or receiving land.

The sensitive environmental receptors are the:

river that runs through the field which is a Site of special scientific interest
river banks that are designated as a local nature reserve

The sensitive receptors are shown on the location map [reference number].

The area of spreading and the surrounding land is arable so there are no animal receptors.

9. Actions to reduce the impacts on identified sensitive receptors

The following measures will be taken to reduce the impact of the activities on the identified sensitive receptors.

Waste deliveries

Waste deliveries to the mobile tanker will be made daily or twice daily as required. The aim is to empty the storage tank before the end of each working day.

The tanker will be filled through a dedicated pipe with a lockable valve. There is a facility available to drain the transfer pipe before disconnection to prevent spillage.

Spreading

Injecting the waste will reduce the potential for odour from the spreading operation.

The predominant wind direction puts the dwellings up-wind of the operation. This should reduce the risk of odour at the dwellings.

Spreading will only be done when weather conditions are suitable to prevent aerosol drift and odour problems. The machine operator will use a dynamic risk assessment to assess the weather and they will record their decision in their operation day book.

The public right of way crosses below the bottom of the field along the river bank. Spreading will only take place:

during the week when the right of way is used less
in line with the required buffer strips to keep any operations more than 10m from the pathway

The machine operator will be instructed to avoid or to stop spreading close to the bottom buffer strip if people are on the adjacent path.

The machinery will run up and down the slope in the areas at the top and bottom of the field assigned for turning. The injection equipment will be lifted before turning at the end of each run.

Machinery turns will be gentle to avoid rutting and wheel slip. There will be no turns in the buffer strips.

Machinery

The umbilical feed pipe will be checked daily for damage. This check and any repairs will be recorded by the machine operator.

All machinery is regularly serviced and spreading equipment is calibrated on an annual basis. Maintenance records and calibration reports for all equipment are available.

Managing run-off

The field slopes down toward the river, the boundary is marked with an established hedge and sheep netting fence. This slope has been identified as a major risk and a catch strip will be placed at the bottom of the field within the 10m no-spread zone. This will be provided by breaking the surface of the stubble with a spring tine cultivator to provide a catch for any run-off that may occur and allow it to percolate into the soil. The injection equipment will be lifted before the machinery reaches the catch strip. The catch strip is shown on the location map [reference number].

The field is not under drained. There will be no spreading in the areas of the field identified for targeted sub-soiling.

Soil depth is more than 40cm over clay subsoil. Infiltration to groundwater is not identified as a high risk.

Emissions to air

Emissions to air post-spreading are not anticipated to cause issue. Spreading will be even and at an application rate designed to allow infiltration without run-off or ponding.

The activities meet the recommendations given in Protecting our water, soil and air.

10. Contingency planning

If it is not possible to accept the waste at the deployment site, the operator will contact the waste producer to stop deliveries.

Machinery is serviced on a regular basis. Replacement field machinery is available and hire vehicles will be used if there is any breakdowns.

Transfer and umbilical pipe failures will be managed by:

a pressure activated switch on the injector supply pump which cuts off if pressure drops below or rises above optimum operating pressures
daily inspection of pipes and clamps
a non-return valve on the mobile tanker input system
supervision of unloading
isolation of the tanker if the transfer pipe breaks

There are enough trained staff to cover sickness.

Operations will not take place:

in heavy rain or if it is forecast within 48 hours
in high or other unsuitable wind conditions
in waterlogged, flooded, frozen or snow-covered ground
when weather conditions are likely to affect operations (a dynamic risk assessment will be done for these events)

11. Compliance with other applicable legislation

The waste is not stored or spread within an NVZ.

I confirm that the benefit statement meets the requirements of the Rules for farmers and land managers to prevent water pollution.