Memorandum from the Waste Recycling Group
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out of date emission standards.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Figures used are out of date and grossly distort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
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
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
EFFECT OF WID ON POLLUTION COMPARISONS
|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