Case Study: Delivery of Full EPR Application for Anaerobic Digestion Plant
Project Summary
Our consultancy was engaged to deliver a comprehensive Environmental Permitting Regulations (EPR) application for a new-build Anaerobic Digestion (AD) facility designed to treat up to 50,000 tonnes per annum of food and agricultural waste. The scope included developing the full permit application, supporting technical assessments, and managing regulatory engagement through to determination.
This was a strategic infrastructure project for the client, forming a key component of their low-carbon circular economy roadmap.
Client: Confidential (Independent Renewable Energy Developer)
Location: Midlands, United Kingdom
Project Duration: 4 Months
Date of Submission: May 2025
Application Type: Bespoke Installation Permit – Anaerobic Digestion (Section 5.4 A1)
Regulator: Environment Agency (EA)
Scope of work
Regulatory Strategy & Scoping:
Determined the appropriate permit type (Bespoke Installation) in consultation with EA.
Prepared and submitted Pre-Application Advice request to clarify application expectations.
Full EPR Application Pack:
Part A & B Forms – Completed with accurate site and operational details.
Environmental Risk Assessment (ERA) – Addressed air, water, noise, odour, and fugitive emissions using EA guidance.
Site Condition Report (SCR) – Baseline condition documentation including borehole logs and soil/groundwater samples.
Management Systems:
Environmental Management System (EMS) aligned with ISO 14001
Accident Management Plan (AMP)
Odour Management Plan (OMP)
Noise Management Plan (NMP)
Waste Acceptance Procedures – Defined LoW codes, pre-acceptance protocols, and record-keeping systems.
Site Infrastructure Plan – CAD drawings showing drainage, bunding, containment, and access routes.
Air Quality Screening – Using EA’s H1 tool and ADMS Lite modelling for NOx and ammonia from CHP exhaust.
Engagement & Submission:
Liaised with EA throughout via Citizen Space and direct consultations.
Responded to Schedule 5 notices promptly with clarifications and additional modelling.
Supported public consultation with stakeholder Q&A documentation.
Challenges & Solutions
Challenges
CHP emissions near a sensitive receptor
Limited historic data for SCR
Tight timeline aligned with funding milestones
Solution
Full dispersion modelling with conservative assumptions and stack redesign
Carried out Phase 1 and Phase 2 intrusive ground investigations
Phased delivery and early submission of draft sections to the EA
Outcomes
Planning Synergy: Permit documents were aligned with planning conditions, reducing post-permission conflicts.
Future-Proofing: Permit allows modular expansion of throughput and technology (e.g., gas-to-grid conversion).
Client Confidence: Risk of regulatory delay mitigated, unlocking investor funding and EPC mobilisation.
Key Takeaways
Early engagement with the Environment Agency is vital to set expectations and reduce downstream challenges.
Robust environmental assessments – even if not mandated – can future-proof the permit and support planning.
Integrated project planning between permitting, design, and finance ensures alignment of critical paths.
"The professionalism and thoroughness from Bioconsult for the EPR submission gave us complete peace of mind. It made a complex regulatory process feel well-structured and manageable. The alignment with the planning process was key to ensure we achieved a full planning submission alongside the EPR application.
The project was delivered to a swift timescale and the interaction throughout made for a seamless delivery. We should have engaged earlier with the team to help us at the development stage and earlier discussions with the planning authority."
Keith Warburton— Chief Executive
Stenergy (Worcester) Limited
Get in touch
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