JohnDeere8530
Member
I am after a Environmental consultant that is based in Southern England. Anyone recommend one as I am struggling to find one....
The reason being is...
Over the last year or so, I have been applying green waste (plant haulm) as a fertiliser produced from large nurseries on the same parcel of land as I farm.
The MO was to move the plant haulm (800t) out of the nursery in November each season, stockpile it in the corner of a neighbouring field (all on same site) and apply after the next harvest at a rate of approx 20t/ha.
Before I started to do this I consulted with the local "EA area officer" whom I know fairly well. He suggested both in meetings and by email what I needed to do. This was...
Obtaining an EWC code for the haulm.
Where to situate the pile and how to look after it until it was applied to my ground 9 months later (September 19 in the first case).
What permits/exemptions I needed to apply for on the .Gov website.
Obtaining an analysis report for the N content of the haulm.
Adjusting the amount of artificial fert I could apply to that crop with the haulm on (taking into account haulm N content)
The list went on.
I asked if I need a waste transfer licence and he thought not, as it was on the same parcel of land, with the same address. ie the haulm was to be applied in the fields immediately surrounding the nurseries
Luckily for me, it was done both verbally and via a dozen or so emails. Once I had done everything all certs were emailed to him and I informed him of my start date (November 18). He was happy with everything
All went well last year and he came and saw the heap etc.
The second season (November 19) I did exactly the same thing (ok pile on different area of land) and now he and his superiors have been in contact saying what I have done was against the regs, so the haulm (800t) will need moving 30miles to landfill. They have now written to me formally stating this.
I explained to him and his superiors that I have followed his word exactly and that he and his colleague were happy last year after seeing the paper trail and pile on the edge of my field. I asked them to revisit old emails.
Bizarrely they said they could not find them. To help, I forwarded the entire email trail to the local officer and asked him to forward to his boss. His boss made contact on the phone wanting to hear my side of things. I referred to the emails that should of been forwarded and the boss said he had not seen them ( I wonder why!) - so I sent them to him direct.
They then had no option other than to acknowledge what was said - however to get out of it they are saying that the EA are not an advisory agency, only a enforcement agency, so I should always use a Environmental consultant and essentially not listen to what advice the EA give out (if any). I guess strictly speaking they are right, although in a very under handed manner.
To me this sounds well off, they are wanting their cake and eat it. On one hand they are saying that I have to listen and act on their stipulation of moving the pile to landfill, but on the other hand I should not listen or act on what they advise me. It is as simple as that.
Of course moving the haulm to landfill is the worst possible way to deal with it from an environment point of view (something that both parties should prioritise) as moving it off site will...
Add 2400 miles of unnecessary transport (30 miles each way/ 20 tonne lorries/ 800 tonnes)
Place further demand of available space in landfill sites
Lose all the nutritional value of the haulm
More artificial N (at a cost to the environment) will have to be manufactured and used.
I have mentioned this to the EA, they seem not in the slightest bit interested about the impact
Any thoughts on this anyone....
The reason being is...
Over the last year or so, I have been applying green waste (plant haulm) as a fertiliser produced from large nurseries on the same parcel of land as I farm.
The MO was to move the plant haulm (800t) out of the nursery in November each season, stockpile it in the corner of a neighbouring field (all on same site) and apply after the next harvest at a rate of approx 20t/ha.
Before I started to do this I consulted with the local "EA area officer" whom I know fairly well. He suggested both in meetings and by email what I needed to do. This was...
Obtaining an EWC code for the haulm.
Where to situate the pile and how to look after it until it was applied to my ground 9 months later (September 19 in the first case).
What permits/exemptions I needed to apply for on the .Gov website.
Obtaining an analysis report for the N content of the haulm.
Adjusting the amount of artificial fert I could apply to that crop with the haulm on (taking into account haulm N content)
The list went on.
I asked if I need a waste transfer licence and he thought not, as it was on the same parcel of land, with the same address. ie the haulm was to be applied in the fields immediately surrounding the nurseries
Luckily for me, it was done both verbally and via a dozen or so emails. Once I had done everything all certs were emailed to him and I informed him of my start date (November 18). He was happy with everything
All went well last year and he came and saw the heap etc.
The second season (November 19) I did exactly the same thing (ok pile on different area of land) and now he and his superiors have been in contact saying what I have done was against the regs, so the haulm (800t) will need moving 30miles to landfill. They have now written to me formally stating this.
I explained to him and his superiors that I have followed his word exactly and that he and his colleague were happy last year after seeing the paper trail and pile on the edge of my field. I asked them to revisit old emails.
Bizarrely they said they could not find them. To help, I forwarded the entire email trail to the local officer and asked him to forward to his boss. His boss made contact on the phone wanting to hear my side of things. I referred to the emails that should of been forwarded and the boss said he had not seen them ( I wonder why!) - so I sent them to him direct.
They then had no option other than to acknowledge what was said - however to get out of it they are saying that the EA are not an advisory agency, only a enforcement agency, so I should always use a Environmental consultant and essentially not listen to what advice the EA give out (if any). I guess strictly speaking they are right, although in a very under handed manner.
To me this sounds well off, they are wanting their cake and eat it. On one hand they are saying that I have to listen and act on their stipulation of moving the pile to landfill, but on the other hand I should not listen or act on what they advise me. It is as simple as that.
Of course moving the haulm to landfill is the worst possible way to deal with it from an environment point of view (something that both parties should prioritise) as moving it off site will...
Add 2400 miles of unnecessary transport (30 miles each way/ 20 tonne lorries/ 800 tonnes)
Place further demand of available space in landfill sites
Lose all the nutritional value of the haulm
More artificial N (at a cost to the environment) will have to be manufactured and used.
I have mentioned this to the EA, they seem not in the slightest bit interested about the impact
Any thoughts on this anyone....
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