Guidance

Landspreading: produce a benefit statement

Updated 4 May 2023

Applies to England

• Publication for Wales

When you apply to deploy mobile plant to landspread waste, you must use an appropriate technical expert to produce your benefit statement.

It must show that your operation is a waste recovery activity resulting in agricultural benefit or ecological improvement.

This guidance is for the appropriate technical expert.

For the type of information that needs including you can use:

• this guidance
• the completed example
• the benefit statement template

Section 1. Qualifications and technical expertise

The appropriate technical expert must have relevant:

• qualifications
• professional experience or vocational qualifications
• professional membership

For example, the Fertiliser advisers certification and training scheme (FACTS) qualification. This is the preferred qualification for assessing agricultural benefit.

For ecological improvement, the Environment Agency expect a person with relevant qualifications, experience or professional membership to produce the benefit statement.

Section 2. Assess agricultural benefit or ecological improvement

You must confirm the:

• deployment is a waste recovery activity
• criteria used to assess agricultural benefit or ecological improvement

To check the deployment meets the requirements for waste recovery, you must follow the guidance given for rule 2.1.3 in Landspreading: how to comply with your permit.

The benefit statement must show how the 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
• 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 – see When you can level the land in Landspreading: how to manage soil health

The Environment Agency use these criteria to assess if your 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

The Environment Agency use these criteria to assess if the proposed waste application will provide ecological improvement.

Ecological improvement when reclaiming 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.

The Environment Agency advise you to consult the appropriate conservation agency if you are creating a habitat.

Section 3. Waste type

You must only accept the waste types listed in your agreed deployment.

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 must provide details of waste storage and spreading in your benefit statement.

Before you spread you must make sure you meet permit rule 2.1.1 R13 storing waste before you spread in Landspreading: how to comply with your permit.

You must only store and spread the waste that is listed in your agreed deployment.

Benefits and risks of storing stackable waste

Consider the benefits and risks of these common types of storage.

Benefits and risks of using a field heap

To meet rule 2.3.1 in your permit you must comply with these operating techniques for field heaps.

A field heap must:

• occupy as small a surface area as is practically required to support the heap and prevent it from collapsing
• not be located within 30m of surface water if the land is steeply sloping

Steeply sloping means land sloping 12 degrees (1 in 5 or 20%) or greater.

A field heap must be at the place where the waste will be used. This can be in or on the edge of the field. It may also be in a farm building, yard area, silage clamp, concrete pad or area of hard standing.

Consider these benefits, they can be:

• easy to set up and simple to use
• close to the spreading area
• kept small and topped up with deliveries during spreading

Consider these risks, the potential for:

• pollution from leachate moving through land drains or surface run-off
• odour and dust
• pests and scavengers
• mud and debris on adjacent roads from waste delivery and collection
• damage to the soil from nutrient enrichment
• damage to the soil from compaction and rutting by machinery
• complaints if unsightly

When deciding where to locate the field heap, you must be able to meet the requirements for storing manure in Rules for farmers and land managers to prevent water pollution.

See also Storing organic manures in nitrate vulnerable zones.

Benefits and risks of using an on-field concrete pad or hard standing

You can use on-field concrete pads or hard standing for storing solid stackable wastes or siting mobile tankers.

This method allows for ease of handling when loading or unloading. It can provide a more efficient way of handling the waste. For example, less spillage and damage to soil.

Benefits can include a reduced potential for damage to the soil from compaction and rutting by machinery.

Consider these risks, the potential for:

• pollution from leachate, particularly if there is no collection facility such as an effluent tank
• odour and dust
• pests and scavengers
• mud and debris on adjacent roads from waste delivery and collection
• a permit breach if it is not at the place of storage
• complaints if unsightly

Benefits and risks of using a farm building, yard area, or silage clamp

These methods allow for ease of handling when loading or unloading.

Consider these benefits:

• contained leachate collection may be present
• secure storage

Consider these risks, the potential for:

• poor farm infrastructure causing pollution
• proximity to sensitive receptors
• odour and dust
• pests and scavengers
• a permit breach if it is not at the place of storage

Benefits and risks of storing non-stackable waste

Consider the benefits and risks of these common types of storage.

Benefits and risks of using a mobile tanker or nurse tank

This method can:

• be flexible
• be relocated to prevent damage to the soil
• provide secure storage
• reduce odour if it is a sealed container

Consider these risks, the potential for:

• inadequate site security
• spillage and damage to the soil from nutrient enrichment at filling and draw off points
• damage to the soil from compaction and rutting by machinery
• mud and debris on adjacent roads from waste delivery and collection

Benefits and risks of using a purpose-built lagoon or permanent tank

Consider these benefits, it:

• is a permanent engineered structure, such as a slurry store
• has a constructed access – reducing the risk of machinery damaging the soil by compacting or rutting

Consider these risks, the potential for:

• accidental mixing of waste with other materials in the tank
• inadequate site security
• rainwater collection
• not keeping an adequate freeboard
• lack of maintenance
• odour, pests, and scavengers – if open topped
• a permit breach if it is not at the place of storage

Benefits and risks of using some common spreading techniques

You must consider the benefits and risks from the spreading technique.

The technique must:

• suit the waste stream, receiving land and current or future crop
• apply the waste to the receiving land at the application rates you state in your benefit statement
• minimise the potential for pollution caused by over-application, poor spreading, run-off, ammonia volatilisation and nuisance from odour, noise and dust

Benefits and risks of using rota spreaders, rear discharge spreaders or dual-purpose spreaders

You can use these techniques for applying solid and semi-solid wastes to the surface.

A rear discharge spreader spreads the waste evenly.

The benefits and risks from ammonia loss vary. It can be low or moderate.

The ammonia loss is relative to the percentage of dry matter and percentage of total ammoniacal nitrogen in the material, and the time it takes to incorporate after spreading.

Consider these risks, the potential for:

• crop damage, such as from smothering
• offensive odour from generating dust
• pests and scavengers
• soil structural damage, such as from rutting or compaction if spread on the wrong soil conditions
• direct discharge into surface water if spread too close

Benefits and risks of using low trajectory irrigators or pulse jet irrigators

You can use these techniques for applying liquid wastes to the surface.

The benefits and risks from ammonia loss vary. It can be low or moderate. The ammonia loss is relative to the percentage of dry matter, the percentage of total ammoniacal nitrogen in the liquid waste, droplet size and soil infiltration rate.

Consider these benefits, it:

• allows for low application rates for example, less than 50m3/ha
• can be used on established grassland
• can spread accurately, subject to good management and supervision

Consider these risks, the potential for:

• drainage to and pollution of groundwater and groundwater-dependant surface water when spread in unsuitable soil or weather conditions
• over application if spread in unsuitable conditions
• nitrate leaching to groundwater during winter months
• direct discharge into surface water if spread too close
• potential wind drift through a pulse irrigator in a moderate breeze or above

The risk of run-off including through land drains where present, can be due to:

• poor supervision
• use on an inappropriate soil
• unsuitable weather conditions
• equipment failure for example, where anti-pollution pressure and flow switches are not used or are broken

Benefits and risks of using high rate irrigators or rain guns

You can use these techniques to apply liquid waste to the surface.

Consider these risks, the potential for:

• moderate to high ammonia loss relative to the percentage of dry matter, the percentage of total ammoniacal nitrogen in the effluent waste and the soil infiltration rate
• generation of aerosol spray
• pollution to groundwater and groundwater-dependent surface water when the application rate exceeds the field capacity, or if the soil is cracked
• nitrates leaching to groundwater during winter months
• an increase in the risk of run-off through land drains where present if spreading in unsuitable soil and weather conditions
• reduced spreading accuracy and ponding of the liquid waste
• direct discharge to surface water or through run-off where the application rate is greater than soil infiltration

Benefits and risks of using non-precision broadcast methods

For surface application with non-precision broadcast methods, you can use a vacuum or a pumped tanker fitted with a splash plate or nozzle to apply liquid and slurry wastes to the surface.

A pumped tanker achieves improved spreading accuracy when fitted with a positive displacement pump. A vacuum tanker may reduce spreading accuracy.

Consider these risks, the potential for:

• high ammonia loss, particularly if the liquid waste is not incorporated immediately after application
• aerosol spray (greater than 4m above ground level) causing drift, ammonia loss, lower accuracy and ponding when using a high trajectory method – the Environment Agency consider this a higher risk relative to other spreading methods
• crop damage
• nitrate leaching to groundwater during winter months
• run-off, including through land drains where present, and soil structural damage when spreading in unsuitable soil and weather conditions

Benefits and risks of using precision methods

You can use band spreaders and trailing shoe spreaders to apply liquid and slurry wastes to the surface. The Environment Agency consider this a lower risk than non-precision methods.

Benefits can include:

• low ammonia loss, subject to good soil infiltration
• ability to use low application rates – for example, of less than 50m³/ha
• that it is suitable for standing crops, such as arable and root using tramlines or rows, and on established grassland
• low risk of crop damage

Higher specification band spreaders and trailing shoe spreaders can:

• achieve improved spreading accuracy
• maximise nutrient use
• minimise nutrient loss

Consider these risks, the potential for:

• nitrate leaching to groundwater during winter months
• run-off and soil structural damage where spreading is done in unsuitable soil and weather conditions
• tramlines and rows between crops may form pathways for run-off (by acting as shallow ditches) - made worse if planted down a slope
• simple band spreaders provide reduced accuracy across spread width relative to other spreading methods

Benefits and risks of using shallow injection

You can use this technique to inject between 5 and 10cm below surface level to apply liquid and slurry wastes to the sub-surface.

Benefits can include:

• a low (open slot) to very low (closed slot) ammonia loss, except when injected in very dry or stony soil where the waste is likely to break the surface
• ability to use low application rates, for example of less than 50m³/ha
• improved spreading accuracy in favourable soil conditions, maximising nutrient use and minimising nutrient loss
• reduced risk of odour

Consider these risks, the potential for:

• crop damage
• greenhouse gas emissions, such as nitrous oxide and methane, where injected waste concentrates in and around the injection slit and where anaerobic conditions develop
• nitrate leaching to groundwater during winter months
• high risk of run-off and drainage to land drains if injected down slope, and if applied in clay soils at or near to field capacity, even at low application rates
• reduced spreading accuracy in wet clay soils, where horizontal movement between injection slots is restricted by smearing and sealing of the clay by the disc

Benefits and risks of using deep injection

You can use this technique to inject liquid and slurry wastes to greater than 15cm below ground.

The Environment Agency do not expect you to use deep injection on soil that is:

• shallow
• overly stony or cracked for example, clay
• on soils at or near field capacity
• if the soil has not dried out
• on wet heavy soils such as clay soils

Doing this may cause damage to the soil and unacceptable nutrient loss through leaching and drainage of the waste. This is likely to cancel out any benefit your treatment gives the soil.

You must only use deep injection on soil that is sufficiently dry. This will enable the soil to loosen and fracture as the wing of the deep injector cuts through it. It will also allow high pressure (500 to 700KPa) injected effluent (more than 100m³/ha) to move horizontally and achieve an acceptable spread pattern. This method is not a good choice during the winter in all soils. Wait until the end of soil drainage when the soil is dry enough.

Benefits can include:

• recognised risk management techniques when applying ABPs to land
• reduced risk of odour

Consider these risks, the potential for:

• significant damage to grassland
• greenhouse gas emissions, such as nitrous oxide and methane, where injected waste concentrates in and around the injection slit and where anaerobic conditions develop
• high risk of waste draining beyond crop use and polluting groundwater or groundwater-dependant surface water from light soils at or near field capacity
• very high risk of run-off polluting surface waters, land drains, smear channels from heavy soils at or near field capacity
• high risk of run-off where soil is very dry and or cracked
• high risk of nitrate leaching to groundwater during winter months due to poor spread pattern and very high application rate
• soil structure damage in wet soils
• soils smearing and sealing when used in wet soils at or near field capacity

Wet soils at or near field capacity restrict horizontal movement. Soils such as clay have limited capacity to hold effluent against drainage. Risk of drainage is increased as the restricted horizontal movement causes an already very high application of effluent to concentrate around the wing. Clay soils can smear and seal as the wing passes through the soil.

Section 5. Operational details

Provide information on the proposed operations.

State how and when the waste will be spread and how the waste will be used:

• 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 using liquid wastes, state if:

• any mole draining or sub-soiling is planned
• there 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

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.

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

Provide information on what benefits the deployment will give.

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

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

See Landspreading: provide a waste and receiving soil analysis for how to give the correct information.

The Environment Agency expect your deployment to form part of the land occupier’s nutrient management plan. If your deployment proposes to rectify a deficiency of one essential plant nutrient (at a level recommended by the Nutrient Management Guide RB209), you must not apply other nutrients unnecessarily.

You can only apply nutrients that the soil and crop needs. Over-applying nutrients is unlikely to be a waste recovery activity and may cause pollution.

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.

The Environment Agency 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 appropriate expert advice to work out how to add and correct deficiencies of other trace elements.

If you set plant nutrient levels above 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 – the Environment Agency do not accept unpublished, theoretical or laboratory-based experimental data
• demonstrate how your deployment is a waste recovery activity

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.

Managing other soil properties

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

• the water content of the soil
• soil pH
• carbon to nitrogen ratio of the soil
• soil and crop nutrients]
• contaminants
• pests and diseases
• salty whey and other high conductivity waste
• soil organic matter and applied agrochemicals
• organic manures
• oil and fat trap wastes

You can also find guidance on when you can level the land.

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

Application rates

Application rates quantify the amount of nutrients, PTEs or other contaminants that will be added to the soil. Your agreed deployment 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).

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. Your benefit statement must outline 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.

Your benefit statement must state the proportion of each waste stream in the mix.

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

When applying more than one waste to the same area 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.

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. The Environment Agency may ask for more information if the benefit statement does not adequately address any identified potential hazard.

Use the receiving soil and waste 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 soil and waste analyses in tables, like Tables 2 and 3 in the completed example.

Limits for PTEs

Your deployment must 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. See:

• section 6.3 PTE limits in soil used in arable farming

• section 6.4 PTE limits in soil used as grassland

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 dry solids. 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 the information as shown in 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 in kg/ha from the application of the waste in t/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 receiving soil and waste analyses.

For further details on:

• PTEs see Landspreading: provide a waste and receiving soil analysis
• metals and other substances see effects of some metals and other substances in soils under Manage contaminants in Landspreading: how to manage soil health

pH

The pH of the soil 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 ABP 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.

See Landspreading: how to manage soil health for information on any other potential negative impacts to soil.

Include any potential negative impacts from trace elements.

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.

Potential negative impacts to land and soil

Provide details of other potential negative impact such as:

• from storing the waste
• 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. These are examples of sensitive receptors:

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

You must consider places of nature conservation and woodland. See:

• find protected areas of countryside – provides information and a search option for different kinds of protected areas

• ancient woodland, ancient trees and veteran trees: protecting them from development – although aimed at redevelopment it includes useful definitions and where to find out more information

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 the measures you will put 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 soil 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 can help to reduce the impact to 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 the impact of wind direction

Include information on how you will protect:

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

Provide information on 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 your written management system.

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 you spreading your waste for extended periods, your contingency plan must make sure you will manage the waste in a way that meets the requirements of the waste duty of care.

Provide details your procedures for when spreading cannot take place or will have to stop. These are set out in your written management system. You can also use a dynamic risk assessment.

For example, consider and plan for the following:

• prolonged waste storage – such as beyond the time allowed on your deployment as agreed with the Environment Agency
• unsuitable ground conditions
• machinery breakdown, transfer and umbilical pipe failure
• staffing problems due to sickness, holiday or other reasons
• exceptional circumstances such as prolonged adverse weather

The Environment Agency accept that prolonged adverse weather may affect when you can spread. You must contact them if this is an issue.

Section 11. Compliance with other applicable legislation

State 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 you will give the landowners relevant 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.