Select Committee on Environmental Audit Memoranda


Memorandum from the Waste Recycling Group plc

  There has been much debate during the Environment, Transport and Regional Affairs Select Committee inquiry into delivering sustainable waste management about the contribution that municipal waste incinerators (EFW) can make to the Government's Waste Strategy and the environment. It appears that the environmental case against the use of these incinerators has been distorted by the use of out of date emission standards. This has resulted in the Select Committee taking a very negative view of incinerators. Municipal Waste Incinerators can make a significant contribution to the 10 per cent renewables target if this error is corrected. The error is to be found in two documents; in the DTI consultation document, New and Renewable Energy, Prospects for the 21st Century and the DETR's Waste Strategy 2000. Standards with which new municipal waste incinerators have to comply with have been drastically improved by the adoption of the Waste Incineration Directive (WID) but this improvement has been overlooked by the DTI and the DETR.

  Figures used are out of date and grossly distort the conclusion. The effect of using the old emission standards for any new municipal waste incinerators results in showing only a small environmental benefit. If the new standards for emissions are used the environmental benefit is considerable as they are far cleaner than fossil generators. It is interesting to note that the Government also made the same mistake in its Waste Strategy 2000, the result of which is to represent any new municipal waste incinerators as worse than landfill. If the new emission standards are used these incinerators are shown to reduce pollution (and green house gas) by replacing fossil generators and making a significant contribution to environmental improvement.

  See page 213 of New and Renewable Energy, Prospects for the 21st Century, Annex B Supporting Analysis. The table compares the emissions from incinerators and power generators in g/KWh terms. It is based on emission standards before the Waste Incineration Directive came into effect . The incineration figures in the Annex B were based on the existing levels of emissions from incinerators. The new standards are considerably higher than existing standards.

  It is necessary to look at another report to track down the emission standards actually used which is AEAT 2945 also by Tom Thorpe see table 1b for the same g/KWh table and page 67 for the emission values used, attached.

  The likely emission values should really be used for any new plant and these will be even less than the WID values. This is the basis of the data in my spread sheet.

  To demonstrate the effect of the changes I attach a table with comparisons. This error needs correcting to prevent significant policy decisions being based on incorrect data.

  The debate as to which fossil fuel generation will be replaced by renewables needs addressing also. If 10 per cent renewables come on stream then this will force the closure of some fossil stations which will not be the new gas stations, it will be the less efficient coal stations. This should be identified. A similar error occurs in the Waste Strategy 2000 part 2 page 188 table C4.

  The chair of the Environment Select Committee says that EFW has environmental costs higher than landfill and quotes the Government's Waste Strategy 2000, which shows benefits of EFW in comparison to landfill when displacing coal but not when displacing the average mix. The chair argues that this should be a reason to tax EFW and exclude them from contributing to the renewable 10 per cent. Great store is being placed on this table.

  The table is an extract from the old Coopers and Lybrand Report referenced in the waste strategy. It was actually first published on 19 May 1996 not 97 as stated in the reference. I've got a copy and a short RR Forum review of same by AEA if you want a copy.

  It was actually carried out in 1995 and looked at the costs and benefits projected for a period up to 2001 based on figures from 1993. Emissions are all pre-WID. This report was published before the WID was in place.

  The report is out of date and does not reflect the lower emissions from the new generation of incinerators. If it was redone with WID numbers, EFW would come out with environmental benefits because EFW post WID is much better than even the average mix of fossil fuels.

  The Environment Select Committee is basing its arguments on out of date information.

  Attached is my comparison of EFW to fossil per KWh.


Emissions g/KWh
MSW Incineration
Average Mix
All above from Annex B DTI New and Renewables etc
based on old standard of mg/Nm3, CO2 stays the same
New standard mg/Nm3 WID.
likely operating conditions for WID
MSW Incineration g/KWh
new standard
MSW Incineration g/KWh likely
Likely emission

January 2001

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