MEMORANDUM BY BRIGHTSTAR ENVIRONMENTAL
(DSW 86)
INTRODUCTION
1. Brightstar Environmental (BE) is a subsidiary
of Energy Developments Limited an Australian listed company who
are the third largest dedicated renewable power generation company
in the world. EDL has been operational in the UK for the last
four years developing projects under Non Fossil Fuel Obligation
(NFFO) from landfill gas, and employs around 70 people.
2. The Company has developed a new resource
recovery process in Australia known as Solid Waste to Energy and
Recycling Facility (SWERF) which offers an environmentally acceptable
and sustainable waste management solution, diverting household
waste from landfill through materials processing, recycling and
energy generation.
3. SWERF provides an example of emerging
technologies that can be integrated in a single community-sized
facility to deliver the UK Waste Strategy. The unique features
of the SWERF technology are:
— front end resource recovery similar
to a dry recyclable Materials Recovery Facility (MRF) that maximises
recycling prior to energy recovery by thermal reformation into
a clean synthesis gas, not incineration;
— flexible modular configuration allows
for changes to plant configuration over the life of a project
to meet changing waste characteristics;
— front end processing allows the diversion
of recovered biomass into alternative value-added products including
certified bio-fertiliser;
— advanced thermal processing allows
value adding to inert by-products not possible from incineration
plants;
— advanced thermal processing allows
significantly higher quantities of renewable electricity to be
generated than currently available from incineration;
— maximising revenues from recycling,
power generation and by product sales provides for gate fees that
are competitive in the current waste disposal market place;
— modular advanced thermal processing
and power generation provides for insignificant visual impact,
no 70 metre tall chimney stacks or cathedral-like buildings;
— advanced thermal and power generation
technology and closed loop design of heat recovery systems minimise
environmental impact.
4. SWERF includes the use of advanced thermal
processing technology based on pyrolysis and gasification which
offers a clear and efficient process that is viable at small scale
and therefore sized to meet a local community's needs. The process
will meet the new EU waste incineration/gasification emission
levels, and can deliver the targets nominated in the national
Waste Strategy at costs competitive with landfill plus Landfill
Tax.
5. After a significant period of development
and commercialisation of the technology in both the United States
and Australia, BE is now seeking to develop its first projects
in the UK and Europe. Without doubt UK waste market conditions
have been enhanced by the publication of the Government's new
National Waste Strategy for England and Wales which is underpinned
by the move away from landfill towards sustainable waste management
which includes high levels of recycling and resource recovery.
6. We therefore applaud the Government for
its commitment to achieving these targets which should present
a tremendous opportunity for new emerging waste management technologies
to be developed in the UK. BE is one company that is committed
to delivering the SWERF technology which without doubt would significantly
contribute to the achievement of this strategy.
7. However, we believe that the following
issues will hinder the development of projects in the UK and influence
the implementation of the National Waste Strategy.
RECYCLING
8. Whilst we welcome the introduction of
higher resource recovery targets, and more importantly statutory
requirements, we believe that too higher emphasis is being placed
on kerbside collection and composting above creating viable markets
for recycled products.
9. We agree that kerbside collection provides
high quality recyclables, however evidence to date suggests that
the economic costs for kerbside collection schemes are prohibitive,
and that separate collection systems are not environmentally sound.
Recycling via this method is also totally market dependent and
evidence to date suggests that schemes have failed financially
because of the insecurity of the commodity markets particularly
for recyclates.
10. The SWERF provides inherent flexibility
to take account of these market fluctuations. SWERF maximises
the recovery of materials for recycling including glass, metals
and plastics. Where traditional recycling routes are not available
for materials, such as plastics and non-recyclable residual organics,
its energy value would be utilised by conversion to electricity.
It is not incineration by the back door, the energy is converted
into a clean synthesis gas for use in high efficiency lean-burn
gas engines.
11. Composting appears to be seen as the
"Holy Grail" solution in meeting the initial recycling
targets. Whilst composting has without doubt some potential to
offer a recycling solution, even success to date has been limited
due to the markets available and the inconsistency of material
that can be produced on a long term basis. It is rapidly becoming
apparent that low cost windrow composting will not be an environmentally
viable solution and more intensive and more expensive European
technologies are likely to be required.
12. The UK industry appears almost blindly
to be walking down the composting route where as the evidence
from other European countries who have been working in this area
for significantly more time than the UK, is to move away from
composting into more technological and environmentally sustainable
solutions. There is similar evidence in Australia where composting
has failed due to poor quality inconsistent material and lack
of sustainable markets. SWERF has the capability of diverting
biomass into a biological process that produces a bio-fertiliser
with certified nutrient content.
13. Our belief is that simply adopting kerbside
separation and a reliance on composting will not deliver the recycling
targets. Recycling markets must be stimulated and more flexible
resource recovery systems implemented that cater for market fluctuations.
MARKETS FOR
PRODUCTS
14. The viability for any new technology
for the resource recovery of waste will be dependent on markets
for the materials produced and we welcome the commitment that
has been made to develop markets for recycled materials.
15. In addition to establishing markets
for traditional recyclables, other markets will need to be developed
for by-products from the emerging waste processing technologies.
To date little has been achieved in the UK in this area due to
the questionable quality of bottom ash from incinerators. The
UK Government's support and assistance will also be needed to
achieve secondary markets to encourage and promote new emerging
technologies into the UK market place.
INCINERATION
16. We note that significant discussion
has centred on the role for incineration in delivering both the
waste strategy and European Landfill Directive. However little
reference has been given to new emerging technologies. In particular
the use of advanced thermal conversion processes that avoid the
process risks of burning a low quality heterogeneous solid fuel
ie incineration of household waste.
17. Whilst, mass burn incineration deservedly
stands as the benchmark for emerging technologies to be measured
against, it is not the only available solution.
18. The emotive arguments put forward by
philosophy driven idealists do not help objective assessment of
the available solutions. In the short term, recycling cannot solve
the UK's waste problem and thermal processing of residual non-recyclable
organics is inevitable. The long term solution may well be different
when consumers habits and the packaging industry have fundamentally
changed.
RENEWABLE ENERGY
19. The attraction of the recovery of energy
from waste whether by biological or thermal processing, is the
ability to sell the main product ie energy relatively simply but
more importantly with some security of price and market, quite
different to other recycled commodities.
20. Electricity from waste processing plant
has always qualified as renewable energy and to date could be
sold under a secure long term contract offered as part of the
Non Fossil Fuel Obligation (NFFO) process.
21. Under the New Electricity Trading Arrangements
(NETA), it is proposed that NFFO will be replaced by an obligation
on the electricity supply companies to purchase a proportion of
renewable energy. It is intended that this Renewable Obligation
(RO) will ensure that the Government's renewable energy targets
will be met by 2010.
22. Energy from waste (EFW) has always been
viewed as a key market supplier of renewable power (as under NFFO),
however moves by the EU to exclude EFW as a "renewable"
is we understand to be considered by the UK government. The result
of this could be catastrophic to energy from waste industry as
not only would the price of power produced from waste be significantly
reduced, any security or market would be lost.
23. The result would be significantly higher
gate fees to cover the loss of energy sales, or the lack of financially
viable projects.
24. Without EFW it will not be possible
to meet the targets within the waste strategy and the EU Landfill
Directive. In addition unless EFW is considered "renewable",
then by definition it cannot be considered part of a "sustainable"
waste strategy.
25. SWERF through ATC provides greater energy
recovery than traditional combustion technology, and as such has
the potential to deliver significant environmental benefits at
gate fees which are comparable with current landfill prices plus
landfill tax.
26. As such we call on the government to
press for the reinclusion of EFW as a renewable source of energy
within the EU, and for the inclusion of energy from waste as an
integral part of the RO in order to provide a secure market for
the sale of power at a price which will ensure competitive and
viable projects.
PROCUREMENT
27. A waste processing facility needs waste
to process. Without a guaranteed input of material then a project
cannot hope to be viable whatever the gate fee.
28. In order to be viable, large capital
projects such as waste management facilities need to secure waste
management contracts generally awarded by local authorities. In
awarding contracts local authorities will generally seek a risk
free position and are therefore likely to source robust technology
which has generally been proven in the UK, and is able to guarantee
performance.
29. As a new entrant to the UK waste industry
with a new emerging technology, it is therefore virtually impossible
to secure a local authority contract under these circumstances.
Even if a company was prepared to build a facility without a contract
being in place, then the plant would still not be able to attract
MSW from a local authority due to prescriptive procurement rules.
30. We believe that this alone is one of
the major hurdles to new technology being developed in the UK.
Local Authorities are rightly unable to take the risks associated
with contracting to new technology, even though there is unlikely
to be any financial risk to the public purse.
31. If the Government is serious about the
attraction of new technology into the UK, then they must be proactive
in promoting and encouraging new technology and more importantly
create the conditions which allow new entrants to enter the market
and compete for waste on a level playing field.
EU LANDFILL DIRECTIVE
32. In order for the UK to meet the targets
set by the Waste Strategy and seek to achieve sustainable waste
management, the move away from landfill must begin now.
33. The derogation to the EU Landfill Directive
to be opted for by the UK Government will mean that the targets
will not begin to bite for at least another 10 years. As such
there will be little incentive for the industry to move away from
the landfill in the short to medium term, and result in the lack
of promotion and investment into new more environmentally sustainable
technologies.
34. As such we call on the Government to
embody the full requirement of the EU Landfill Directive to assist
in implementation of the current strategy.
September 2000
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