House of Commons - Environment, Transport and Regional Affairs

Select Committee on Environment, Transport and Regional Affairs Memoranda

MEMORANDUM BY THE ENERGY FROM WASTE ASSOCIATION (DSW 35)

INTRODUCTION

EWA is a non-profit making Trade Association representing the key developers and operators of energy from waste (EfW) plants in the UK. The Association's membership includes major waste companies active in creating and implementing sustainable waste management solutions including recycling, composting, EfW and landfill. These companies have many years of continuous operating experience and have access to state-of-the-art technology complying with strict environmental standards. (Membership details are given at Annex 1).

EWA has an active lobbying, marketing and communication programme and is a major consultee on all matters affecting the EfW industry across energy, waste, environment, research and education.

BACKGROUND

EfW has an increasingly central role to play, both in the development of sustainable integrated waste management practices and the delivery of the UK Government's recovery targets under "Waste Strategy 2000". However, EfW has a much broader "resource recovery" remit than just energy, including wider materials recovery. Thus, it also complements recycling targets, and forms an integral part of sustainable waste management activities.

EWA welcomes the Government's recognition in "Waste Strategy 2000" of the important role that EfW has in the UK's future integrated waste management policies. We applaud its statement that "In future, we must make much greater efforts to reduce waste and substantially increase re-use, recycling, composting and recovery of energy from waste".

The terms of reference for this enquiry are broad, covering all aspects of the Government's strategy. These are complex issues and, until we see the details of the Government's proposed implementation mechanisms, it is impossible to say whether the strategy can be attained. In the meantime, EWA is pleased to comment on "Waste Strategy 2000", particularly with reference to the part that EfW must play in attaining the stringent, mandatory targets therein and delivery of more sustainable waste management.

THE ROLE OF ENERGY FROM WASTE

The Committee's terms of reference invite comment on whether the strategy will result in "increased use of incineration as a waste disposal/recovery option" and what the consequences of any increase might be.

EfW technologies are complex and, like all technologies, are being constantly developed and refined. It is simplistic therefore to refer generally to "incineration", a term that, in our view harks back to the generation of plants built in the 1960s and 1970s. Modern EfW technology is very different in terms of both its potential environmental impacts and the ways in which it can be embodied within wider integrated waste management approaches. A brief description of the various thermal technologies would be beneficial to the discussion.

Thermal Technology Processes

EfW is the combustion/oxidation of waste under controlled conditions in which the heat released is recovered for a beneficial purpose such as electricity production or the provision of steam or hot water for industrial or domestic users. Combined heat and power (CHP) plants provide both electricity and heat. Key technologies are:

— Mass burn: the most widely used technology in the EfW industry, involving feeding MSW directly into the boiler unit, where it is burned on a grate or hearth without prior pre-treatment such as size reduction, shredding or material removal.

— Refuse derived fuel (RDF): involves sorting household waste to remove recyclable material and wet putrescibles. The combustible material is then shredded and either burnt directly or compressed into pellets prior to combustion.

— Fluidised bed: entails a combustion system in which a fine inert material such as sand is maintained in a fluid condition by air blowing upwards through it. This is used in combination with processed waste fuels such as RDF.

— Gasification: involves the breakdown of hydrocarbons by heating waste in a low-oxygen atmosphere to generate a low heat content gas called syngas for burning an engine or turbine.

— Pyrolysis: involves heating waste to a high temperature in the absence of oxygen to produce secondary fuel products such as char, pyrolysis oil and syngas.

In general terms, the cost of using mass burn technology compares favourably with the alternative cost of sending waste to landfill. The latter three methods are relatively new technologies and disposal costs are currently considerably higher than conventional mass burn EfW plants. Moreover, gasification and pyrolysis, in particular, have yet to establish sound track records in performance at commercial levels of operation. There are currently only a few demonstration projects at large scale in Germany and Japan. Therefore, the technical and economic feasibility cannot be described as "fully demonstrated". So, although these processes may, in the long term, offer an alternative to mass burn incineration for replacing landfill as the primary disposal option, the appropriate proven performance references are not available and for the foreseeable future, mass burn plants will dominate the EfW industry.

Meeting the Targets

EfW has the potential to contribute significantly towards satisfying a number of important targets both in the energy and waste sectors:

— "Energy from waste plant can displace the need to use more polluting fossil fuels to generate heat". EfW is a CO2 neutral process and has an important contribution to make towards achieving the Kyoto greenhouse gas emission targets by avoiding both CO2 emissions (substitution for fossil fuel fired generation) and methane emissions (diversion of waste from landfill). The latter, of course, is some 20 times more potent than CO2.

— "The Government and the National Assembly will continue to encourage the recovery of energy from waste, where appropriate, as part of their renewable energy strategies." EfW has an important role to play in achieving the 10 per cent Renewable Energy targets by 2010. DTI estimates that by 2010 EfW could contribute up to 17 per cent of renewable energy but the inclusion of EfW within the Renewable Energy Obligation is absolutely vital.

— "The Government and the National Assembly believe that recovery of energy from waste, through using it as a fuel, has an important part to play alongside recycling and composting in a system of sustainable waste management." The industry will play a crucial role in meeting the statutory diversion targets of the EU Landfill Directive, which is fundamental to the sustainability messages in Waste Strategy 2000.

How demanding are the targets?

The Landfill Directive sets very ambitious targets for the reduction of biodegradable MSW sent to landfill in the UK. This is illustrated in Table 1 below. This is based on the 1998-99 MSW generation figure for England and Wales of 28 million tonnes and assumes that 60 per cent of MSW is biodegradable. It considers scenarios of zero, 1 per cent, 2 per cent and 3 per cent cumulative increase in waste generation per annum.

Table 1

Annual tonnage (millions) of biodegradable MSW to be diverted from landfill to satisfy the Landfill Directive

Year	Annual Increase in Waste Generation
	0%	1%	2%	3%
2010	3.8	5.7	7.4	9.5
2013	8.1	10.6	13.0	16.0
2020	10.7	14.6	18.9	24.3

The difficulty in achieving the targets cannot be disputed since, by 2020, alternative disposal options will have to be found for 64 per cent (at best) and 145 per cent (at worst) of the current annual biodegradable MSW generated.

In order to meet the Landfill Directive diversion requirements, "Waste Strategy 2000" has set specific recovery and recycling/composting targets. These are shown in excerpts from the strategy given at Annex 2. To quantify these targets in real terms and establish how attainable they are, probable growth in waste arisings need to be considered. Again we use zero, 1 per cent, 2 per cent and 3 per cent rates of annual increase in MSW generation for the target years of 2005, 2010 and 2015. Table 2 represents the tonnage of waste from which value would need to be recovered. Table 3 represents the tonnage of waste that would need to be recycled and composted. Table 4 represents the tonnage that remains for EfW, assuming that the recycling and composting targets will be achieved.

Table 2

Annual tonnage (millions) of waste from which value needs to be recovered

Year	Annual Increase in Waste Generation
	0%	1%	2%	3%
2005	11.2	11.9	12.4	13.0
2010	12.6	14.1	15.4	16.9
2015	18.8	22.0	25.2	29.2

Table 3

Annual tonnage (millions) of waste, which needs to be recycled/composted

Year	Annual Increaese in Waste Generation
	0%	1%	2%	3%
2005	7.0	7.4	7.7	8.1
2010	8.4	9.4	10.2	11.3
2015	9.2	10.8	12.4	14.4

Table 4

Annual tonnage (millions) of waste remaining for EfW

Year	Annual Increaese in Waste Generation
	0%	1%	2%	3%
2005	4.2	4.5	4.6	4.9
2010	4.2	4.7	5.1	5.6
2015	9.5	11.2	12.8	14.8

The above data illustrates that in order to satisfy the value recovery targets in Table 2 by 2015, between 33 per cent to 53 per cent of current annual MSW generated would need to be recycled or composted and, assuming these targets are met, 34 per cent to 53 per cent would need to be diverted for EfW treatment. The current annual increase in waste generation is 3 per cent and considerable efforts would be required to stabilise, let alone reduce this rate. In essence, a yawning gap is created between the current situation and that projected for 2020 by the combined reduction in available landfill and increase in MSW generation. During this period alternative disposal options will need to be found for a rapidly increasing amount of biodegradable MSW.

Necessary new EfW capacity

Currently, 200 MW "green" electricity is being recovered from the combustion of 2.5 million tonnes MSW per annum at 11 EfW plants in England and Wales. Assuming a 3 per cent annual growth rate, the amount of waste that will require combustion in EfW plants annually will be 4.9 mt in 2005; 5.6 mt in 2010 and 14.8 mt in 2015. This translates into 400 MW, 455 MW and 1,200 MW electricity production respectively. In order to achieve the targets required by Waste Strategy 2000, the following annual increases in MSW combustion capacity will be necessary:

— additional 2.4mt by 2005 (requires another 12 new EfW plants of average capacity 200,000t);

— further 0.7 mt by 2010 (requires another 3 to 4 new EfW plants);

— further 9.2 mt by 2015 (requires another 46 new EfW plants of average capacity 200,000t or 92 new plants of average capacity 100,000t).

It should be noted that the actual capacity of new EfW plants is likely to vary considerably to suit the catchment area of the waste disposal authority concerned, thus meeting the "proximity" principle of dealing with waste where it arises. There is no optimum size of plant, either in economic terms or in terms of sustainability.

These figures demonstrate that claims in some quarters, that the strategy will lead to a flood of new EfW plants in the UK, are misplaced. Over the next 10 years, the industry predicts that some 15 new plants will be needed—very much in line with the numbers planned by developer companies before the strategy was published. Instead the industry, working with its partners in Local Government, is poised to embark on a realistic, manageable and environmentally responsible programme for dealing with the country's escalating waste problem and adapting to a diminishing availability of landfill space.

Even after 2010, the figure quoted in Waste Strategy 2000 (Part 2) for the requirement of 166 new plants is a gross exaggeration, as shown by our projections above. EWA believes that experience over the next 10 years, with MSW combustion in strictly controlled modern EfW plants that comply with stringent environmental standards, and properly integrated into truly sustainable local waste strategies, will clearly show the way forward for EfW beyond 2010. This will provide the Government, general public and green lobbies with invaluable evidence that EfW is the BPEO alternative to MSW disposal by landfill.

The Government needs to bear in mind that although the EfW industry has the potential to deliver the above capacities, assuming the necessary economic instruments are already in place, certain barriers will still render this a very formidable challenge. The primary barrier lies in the existing planning regime, the structure of which is such that, historically, obtaining planning permission for new facilities has proved to be an extremely slow and arduous process. Rigorous revision of the planning process will be necessary to improve significantly the likelihood of meeting the requirements of the Landfill Directive and other indicative targets.

The Government also needs to make provision for the future diversion from landfill of Commercial and Industrial waste, the 1998-99 waste production figures for which were 30mt and 48mt (excluding Construction and Demolition waste) respectively. Alternative disposal options will have to be found for these waste streams too and EWA believes that the EfW industry will play a significant role, after waste minimisation and recycling initiatives.

THE CONSEQUENCES OF INCREASING EFW

As we have demonstrated, significant increases in EfW capacity are a pre-requisite of the UK being able to meet its obligations under the Landfill Directive. Therefore, the consequences of increased reliance on EfW will be beneficial. The UK will have at least a chance in meeting its strategic objectives in a number of key areas including waste management, renewable energy and reversing climate change.

However, opponents of our industry continue to raise what they see as fundamental objections to the processes involved. Claims, based largely on inaccurate or "selective" data, are often laid against the EfW industry with the intention of creating a negative perspective about what is in fact a proven environmentally responsible and beneficial method of dealing with MSW. For the purpose of clarification, some of these misleading statements are addressed below and placed in a factual perspective.

Common EfW myths

"EfW transforms MSW into ash and small particles that contaminate the environment"

The main residues from EfW plants consist of incinerator bottom ash (IBA) and air pollution control (APC) residues that equate to approximately 25 per cent and 3 per cent by weight respectively of the incoming waste stream. IBA from modern EfW plants is inert and is widely used as a secondary aggregate in road construction and the building industry. APC resides are safely disposed of in licensed engineered landfills.

"EfW causes pollution and emits dioxins"

Modern technologically advanced EfW plants conform to extremely stringent environmental standards and achieve emission levels well within the emission limits set by the legislative authorities. Dioxins are released into the environment throughout the world in trace amounts as a result of a variety of combustion processes including power plants, cement kilns, diesel vehicles, buses, open fires in the home, bonfires, barbecues, jet engines, forest fires and EfW plants. The latter serve as a dioxin "sink" as dioxins which are present in the waste stream are destroyed by high combustion temperatures in the presence of a controlled supply of oxygen.

"EfW limits opportunities for recycling"

Neither EfW nor recycling alone can deal with all MSW generated. EWA advocates an integrated approach, whereby waste should be reduced or reused as far as possible and only then diverted for recycling and composting, where practically and economically feasible and environmentally benign. Residual waste should be treated in an EfW plant ahead of disposal to landfill. Local authorities are required to ensure that the right balance between recycling, composting, EfW and landfilling is reached, the key to which lies in the correct sizing of the planned treatment and recovery facilities at the outset. Experience in other countries, many often cited as the most environmentally sensitive, shows that high levels of recycling and EfW can co-exist—see Annex 3.

"EfW is not required because recycling will increase"

The success of recycling relies on the cleanliness and quality of the resource, the availability of markets and economic prices. A portion of the combustible material in household waste is contaminated by food and is therefore "dirty" and hence would not meet the criteria necessary for recycling in a cost-effective manner. Even a 50 per cent diversion of waste into recycling initiatives would still leave enough heat value in the remaining waste to facilitate the generation of electricity and heat through combustion.

"EfW limits opportunities for the development of other renewables"

There is no evidence that the development of EfW has slowed the deployment of other renewable sources of energy. The planning process is difficult for all proposed waste management facilities as well as renewable energy projects. The impending Renewable Energy Obligation is intended to accelerate the planning and implementation of new renewable projects.

CONCLUSION

"Waste Strategy 2000" says that "The Government and the National Assembly have already put in place a number of instruments designed to reduce the amount of waste produced, and to increase re-use, recycling and energy recovery. But there is more we can and must do." The EfW industry keenly awaits further support and initiatives from the Government to divert waste from landfill and pursue efforts to increase the value that the UK can derive from its waste. EfW offers a long-term, secure and environmentally acceptable BPEO for treating MSW and is essential to the development of successful integrated waste management in the future.

Annex 1

Members of the Energy from Waste Association