The problem with waste soil: Are soil banks the answer? Graham Winter, Senior Advisor, Environment Agency

1. Circular Economy:
The problem with waste Soil
Graham Winter
Senior Advisor: Circular Economy
Strategy
Environment Agency
November 2023

2. What I am going to talk about
• Soil and the circular economy
• Problems with waste soil
• Potential for a Soil bank system
• Next steps

3. Why Soil?
• Soil is a mixture of minerals, organic matter, living animals and
microorganisms, water and gas. It takes hundreds, thousands or even
tens of thousands of years for soil to form – this means it is a non-
renewable resource and it is vital we look after it.
• In 2018, 29.5 million tonnes of soil from construction sites were
disposed of in landfill in the UK 5. Only 0.6 % of this was hazardous,
which means a huge amount of this vital resource is being lost during
construction
• Soil stores carbon - approximately 94% of the UK terrestrial biosphere
carbon stocks (Report101_ERAMMPShortReport_Carboninsoil_Eng_0.pdf)
Home | Soils Task Force

4. Circular Economy definition

5. CE Model
From Linear to Circular, how does
this apply to soil?

7. Why is soil a waste? – discard
• A material is waste if the holder has discarded it. The holder is the
person or legal entity who has the material at the time it’s discarded.
• Assessment of whether a material has been discarded is based on the
actions of the holder.
• A holder may unintentionally, involuntarily or accidentally discard a
material. They may also be required to discard it.

8. The problems with waste?
• High quantities going to landfill
• Storage & handling
• Misdescription
• Quality Protocol
• Permitting mechanisms

9. Managing the problem
• Definition of waste & End of waste
• Definition of Waste Code of Practice
• Waste framework directive – use and storage
• Permits & Regulation

10. Government Commitment

11. • This is a draft proposal only

12. Grondbank – Flanders, Belgium
o Non-profit organisation
o 95% of excavated soil is being reused
o 20 years of operation
o Not legally mandated to use
Grondbank
o Overviews over 160 intermediate
storage and soil remediation facilities
o Soil is accompanied by an identification
form of waste only when is
contaminated or transported to
another region or abroad

13. Excess Soil Registry – Ontario, Canada
o Mandatory digital reporting service
for tracking excavated soils during
construction
o Provided by the Resource
Productivity and Recovery Authority
(circular economy regulator)
o Paused for ~ 1 year due to the
industry not being ready for the
regulatory enforcement
o Under the certain criteria, soil is not
designated as waste

14. Costs of international systems vs. landfill
Price (per ton)
Reuse system Landfill
Grondbank – Flanders,
Belgium
€20 €30
Alberta Soil Reuse
Facility – Alberta,
Canada
$20-56 $40
Excess Soil Registry -
Ontario Canada
$25 flat fee (<10 m3)
$0.02 tiered fee
$100
Clean Soil Bank – New
York, USA
Only transport costs $60

15. Introducing the SRS system – Governance
The SRS governing body should:
• be an autonomous and independent body.
• be responsible for tracking all soil flows in England digitally and
work collaboratively with CL:AIRE (DoWCoP), the regulators and the
landfill operators.
• have established quality management framework for their soil
storage and treatment facilities.
• authorise soil movements to members only.
• provide a digital platform for all members to find the appropriate
location for their needs.

16. Introducing the SRS system – Governance
The SRS governing body should NOT:
• participate in any regulatory activity, but rather inform the
regulators.
• be responsible for finding receiving sites, soil hospitals or hotels,
that is responsibility of the members.
• allow any soil movement without all the appropriate paperwork
being signed off.

17. Introducing the SRS system –
Soil Hotels
• Fixed facility for temporary relocation of clean, natural soils.
• Can operate under current framework with a permit, governed by
SRS but are regulated by the Environment Agency (EA).
•Established quality management framework on soil handling,
storage, soil health and quality indicators.
• Can be publicly or privately owned, but must follow the quality
management framework established by the SRS.
•Soil Hotels will only receive soil if under the Material Management
Plan (MMP; DoWCoP) it has been proven that reuse on-site and
direct transferred have already been explored or there is limited
space available for storage on-site.

18. Introducing the SRS system –
Soil Hospitals
• Fixed facility for treatment of contaminated soils that can be
treated.
• This needs a new framework to be introduced.
• Established quality management framework on soil treatment,
handling, storage, soil health and quality indicators.
• Can be publicly or privately owned but must follow the quality
management framework established by the SRS.

19. Soil Hotel Scenario

20. Soil Hotel Scenario

21. Soil Hospital Scenario

22. Soil Hospital Scenario

23. Scenarios of soil movement under SRS system

24. What do we need to make it work?
• Better understanding of the value of soil
• Economic value of soil
• Independent quality assurance and system
administrator
• Agreed recipes for soils –
• made to order?
• Who decides?
• End-of-waste agreements
• New legislation/regulation

25. New legislation needs?
 Soil specific legislative framework, not just focusing on agricultural
soils, with standards assessing soil health and functions.
 A circular economy framework introducing the SRS system and QPs.
The definition of waste for soils should be reassessed and ensure that
they are viewed as a valuable resource rather than waste!!

26. Changes in legislation?
• Revisions in Waste Regulation to remove all soil following the Soil Hotels’
pathway to not be regulated as waste.
• Revisions in Waste Regulation, with appropriate end-of-waste criteria for soils
following the Soil Hospitals’ pathway, to not be regulated as waste post-
treatment.
• Soil reuse management plan could be mandated under existing Planning or
Construction regulations.
• Review the Landfill Tax lower rate and make it less cost appealing to dispose
of soils.
• Review of the current permitting for storage, beyond the 12 month limit and
the tonnage limit, to allow the soil hotels’ successful operations.
• Review of the current amount and storage time allowance of manufactured
soils, to allow the soil hospitals’ successful operations.

27. Questions / Challenges
• Can we declare clean natural soils as non-waste?
• How do we know it’s clean?
• How can industry agree the ‘non-waste’ recipes for soil?
• Who should decide the soil standards?
• Is there a simpler way to achieve a Circular Economy for Soil?

28. Summary
• Soil is a finite resource
• Increasing pressure on land (and waste disposal)
• Growing appetite for healthy and sustainable soils
• Opportunity to be part of the solution
Graham.winter@environment-agency.gov.uk