Mr. Tony Breton:

I thank the committee for the opportunity to present on behalf of Cré. By way of an introduction to Cré, which is the Irish word for "soil", we were established in 2001 and we are a non-profit association of public and private organisations dedicated to growing the biological treatment sector in Ireland. Cré supports the use of composting and anaerobic digestion, AD, to produce high-quality outputs, assists with the delivery of the Government's waste diversion and bioenergy strategies and targets and promotes the creation of sustainable indigenous jobs. To date, our members have processed over 3 million tonnes of household and commercial brown bin and garden waste.

For context, in February the Intergovernmental Panel on Climate Change, IPCC, issued part two of its sixth assessment report. It emphasises the urgency of taking immediate and more ambitious action to address climate risks. Referring to the patchwork of pledges and ad hoc mitigations undertaken to date, the report states that "half measures are no longer an option". Systems change is now demanded, in the form of “transformation and system transitions in energy; land, ocean, coastal and freshwater ecosystems; urban, rural and infrastructure; and industry and society”, or, in other words, systemic change across the board.To achieve this, it notes that "A sustainable bioeconomy relying on bioresources will need to be supported by technology innovation and international cooperation and governance of global trade to disincentivize environmental and social externalities". The circular economy is based on three core principles, that is, “to eliminate waste and pollution, circulate products and materials and regenerate nature”, underpinned by a transition to renewable energy and materials. Achieving this is a question of design and a willingness to accept and deliver systemic change.

While much of the discussion here is likely to concentrate on the inexplicable failure of successive Governments to provide enabling policy in the area of renewable energy, specifically anaerobic digestion, the most often overlooked aspect of AD is its potential role in redesigning our food systems. For a circular economy and bioeconomy to succeed, there is fundamental need to consider the full circle of activity. In the case of the bioeconomy, it all starts and ends with the soil. It is from the soil that crops are grown and without healthy soils there are no crops. The gold standard for agricultural digestion, using crops and manures, that I am aware of, is Biogasdoneright in Italy. The principles of the Italian system are such that they cannot be ignored when we consider other inputs such as biowaste from brown bins, industrial sludges or commercial food wastes. The system there is designed around soil health and maximising carbon sequestration while minimising other potential environmental impacts caused by inappropriate digestate and land management.

In the UK, which is often seen as a leader in food waste digestion, the dash for gas has, regrettably, led to some unintended economic and environmental consequences. The early deployment of incentives, against a background of not having a policy on food waste collection in England, has forced many wet AD facilities to operate at near zero or at negative gate fees as plants become desperate for feedstocks. This is a perverse situation where the waste generator, that is the polluter, gets paid. The environmental impacts from whole digestate mismanagement include increases in ammonia and other greenhouse gas, GHG, emissions from storage and spreading, microplastics and soil compaction from injection. Today, the UK Government is being forced to rethink digestate management and the industry is seeking alternatives, including pelletisation and composting of digestate.

Belgium, the Netherlands, Austria and Germany, to name but a few countries, take a different approach to that of the UK and the composting of digestates from municipal biowastes is the norm. These countries have similar household biowaste collection systems to Ireland, and in that regard they have either reconfigured existing in-vessel composting facilities or have new-build dry AD systems which, while potentially comparable to biogas yield compared with their wet equivalents, are much more capable of handling the combination of wet food wastes and the more lignocellulosic garden wastes. Dry AD systems will always have a composting phase, whereas wet systems outside of Italy typically do not.

What all these countries have done, and which Ireland fundamentally has not, has been to decide to strategically support anaerobic digestion or indeed the wider biowaste industry. It is true that Ireland has legislation on food waste collections, and we welcome the plans to expand this further, but as shown in our most recent market report, just 15% of waste food is organically recycled in Ireland and almost 50% of the collected biowaste is exported. While still counting towards Ireland’s recycling figures, it seems illogical to be exporting our organic feedstocks and nutrients to other jurisdictions, and this is before we consider the missed opportunity for jobs and local environmental benefits.

It is not just our feedstocks and nutrients being exported. Last week, we heard of a new €30 million grid connection hub for biomethane in Cork. While this is welcome, one member of our association asked me why we are building a biomethane hub connection in an area where there is no biomethane product and no production facilities have planning permission. This member applied to Gas Networks Ireland, GNI, for a grid connection a decade ago. All the permits and permissions are in place, but it has still not been possible to get a gas grid connection, even though the facility is on the grid and all that is required is 1 m of pipe. As it cannot connect to the grid, this facility is currently limiting its generation of biomethane. Additionally, while this member is considering markets for bio-carbon dioxide and thus creating more local jobs in a deprived rural area by expanding production, the facility is currently being forced to sell its biomethane at a low value into the market. Ironically, it appears it is exported to Northern Ireland, where it is used in low-efficiency combined heat and power, CHP, systems because that is where the incentives bring the highest value.

It is commonly agreed that this biogas-to-CHP approach is not the future and that there is an urgent need to move out of the use of gas derived from fossil fuels for heating and to provide low-cost and potentially carbon-negative solutions for heavy goods vehicle, HGV, transport fuels, such as bio-compressed natural gas, bio-CNG, and bio-liquified natural gas, bio-LNG, from biomethane. Beyond fuels, biomethane has potential in the chemical industry as a source of methanol or hydrogen. The point is that AD is proven as a technology. As biogas production and scrubbing technologies improve, so do the market opportunities. The second, and equally important point, is that for biowaste, at least, anaerobic digestion and composting must be considered as complementary not conflicting approaches.

Talking to our members while preparing for this meeting, several themes arose. These included: planning delays, where it can take more than three years to gain consent; delays in the context of the Environmental Protection Agency, EPA, where it can take more than two years, at least, to get an industrial emissions directive, IED, permit; uncertainty, be it over feedstocks, as noted above, or concerning biomethane supports; feedstock quality, as brown bin waste typically has at least 10% contamination; the lack of a national standard for digested biowastes; concern over market distortions; and an urgent need for a pragmatic biowaste policy.

Looking at the global picture, it is clear that anaerobic digestion is being deployed outside Ireland with speed and sometimes with haste by ignoring the wider soils and environmental aspects. This technology has a relevant role in energy, nutrient and food security. As a nation, Ireland has the base point which most countries are missing and that is a clear direction on food waste collection. What appears to be lacking is the courage to join the dots of the bioeconomy circle to take biowaste from soil to biomethane and back to soil.

I again thank the committee for the opportunity to speak today. I invite the committee members to visit an integrated anaerobic digestion and composting facility here. The facility composts biowaste, while the anaerobic digestion treats wet commercial sludges. The biogas produced is used in a CHP engine and is upgraded to biomethane.