Annex 2
THE SUBSTITUTE FUELS PROTOCOL (SFP)
1. The Substitute Fuels Protocol[13]
is non-statutory Environment Agency guidance governing the procedures
for the permitting the use of alternative fuels within cement
and lime kilns. It does not apply to any other industrial process.
2. This guidance supplements the formal
legislative regimes-Integrated Pollution Control, currently being
replaced by the Integrated Pollution Prevention and Control, the
Hazardous Waste Incineration Directive and the forthcoming Waste
Incineration Directive.
3. The Agency developed the SFP following
recommendations made following two House of Commons Select Committee
enquiries into the regulation of the cement industry and alternative
fuels held during the mid 1990s. [14]
4. In view of developments in legislation
since it was introduced, ie Integrated Pollution Prevention and
Control, (IPPC), Hazardous Waste Incineration Directive, (HWID),
Landfill Directive, and the Waste Incineration Directive, the
use of alternative fuels is now much more rigorously controlled,
and consequently the SFP has become superfluous.
5. The SFP is an inflexible regulatory tool
that inhibits innovation and enforces continued reliance on less
environmentally friendly fossil fuels
6. The SFP specifies the arrangements for
public consultation and the technical requirements that operators
must fulfil before they receive an authorisation. The latter include:
6.1 Extensive trials before operators are
allowed to burn the waste-derived fuel on a continuous basis.
The Agency has set a minimum duration for these trials of six
weeks. After completing the trials, operators will return to conventional
fuel while the Agency carries out public consultation on the results;
6.2 Detailed guidance on waste-derived fuel
sampling, including guidance on methods and substances to be excluded
from the fuels. No weight is accorded either to experience or
the results of previous use of fuels at the same or other sites;
6.3 More detailed guidance on emission sampling
frequencies, calibration of instruments and analytical techniques,
including a specification for the minimum number of valid results
that must be obtained.
7. New procedures for extensive public consultation
have been developed in the Tyres Protocol, see below.
8. The SFP guideline is structured in such
a way that even after proactive public consultation and technical
success of the trial, there is a break before progressing to permanent
use of the fuel. At the end of the trial, the operator must stop
using the fuel, reapply for its permanent use and undergo a similar
period of public consultation and protracted technical determination.
The authorisation may then be granted. The large time gap inherent
in the protocol between trial and permanent fuel use also causes
major contractual and logistical problems with potential suppliers.
9. A typical timetable for gaining permission
to use fuels under the protocol is set out in paragraph 13 of
the text.
10. Typically, the time involved in gaining
permanent authorisation is 15 to 30 months. In addition the up-front
costs of plant required to trial are £1 million to £2
million, with trial costs adding a further £600,000 to £800,000.
All of these costs are essentially risk capital, which is forfeit
if permanent permission is not forthcoming. These lengthy authorisation
periods have a significant effect on the payback period. Delays
between the end of trials and the granting of permits are problematic
in terms of continuity of supplies (of alternative fuel to required
quality standards) and operational conditions. [15]
THE COSTS[16]
INCURRED BEFORE
PERMISSION IS
GRANTED TO
BURN A
SINGLE ALTERNATIVE
FUEL AT
A SINGLE
DESIGNATED KILN
ARE:
| Trial Costs:
| |
| £150-250k | Equipment for trial
|
| £100-200k | Trial supervision costs
|
| £250k | Testing/analysis
|
| £50k | Evaluation of results
|
| £50k | Stakeholder Consultation
|
| £600-800k | Total, per location
|
| Plant Costs: | |
| For permanent use, plant cost are £1 million to £2 million
|
11. Once permission has been granted for the permanent
use of an alternative fuel, considerable continuous monitoring
and routine testing is incorporated within the Environment Agency
permits, and is embodied in the Hazardous Waste Incineration Directive,
such that any excursion from the limits imposed would be quickly
ascertained, thus negating the need for the many aspects of the
Substitute Fuels Protocol.
THE TYRES
PROTOCOL
12. A separate protocol that controls the use of tyres
has been issued recently[17]
as a consequence of discussion between the Environment Agency
and the industry over a period of two years. Although this provides
a quicker route in granting authorisations for tyres than the
SFP, nevertheless it imposes significant restrictions before tyres
can be used as kiln fuel.
13. Whilst the resulting document is an improvement over
the SFP; the constraints still applied to this "mature"
alternative fuel are totally disproportionate in view of the proven
environmental benefits of its use.
14. Furthermore, despite this "streamlining",
the authorisation process in the UK still involves substantially
greater preliminary trial work than elsewhere in Europe, where
approval can take as little as two weeks, a typical time in Germany
for an authorization to burn meat and bone meal. Even the traditionally
"green" northern European states as well as France and
Belgium—appear to operate on the premise that burning alternative
fuels is environmentally beneficial and is to be encouraged. See
Paragraph 13 in the text.
15. However, the UK cement industry would welcome the
use of its procedures for stakeholder consultation as a model
for the use of all waste-derived fuels across industry.
OTHER INDUSTRIES
16. There is at present an imbalance within the UK in
the level of scrutiny given to other industries burning alternative
fuels, and far from gaining "first mover advantage"
the cement industry has effectively been penalized as a result
of its pioneering work in this area. For example: Coalite, Bolsover
has been given permission to use tyres in its pyrolysis process.
It obtained this permission without having to follow the either
the Tyres or the Substitute Fuels Protocols. Implementation for
them was quicker, cheaper and involved far less public consultation
than for the cement industry.
13
Substitute Fuels Protocol for Use on Cement and Lime Kilns, Environment
Agency. Back
14
"The Burning of Secondary Liquid Fuel in Cement Kilns";
"The Environmental Impact of Cement Manufacture", op
cit. Back
15
Data from Lafarge Cement UK. Back
16
Tyres Protocol for Use on Cement Kilns: A Supplementary Note to
the Substitute Fuels Protocol, The Environment Agency, November
2001. Back
17
Tyres Protocol for Use on Cement Kilns: A Supplementary Note to
the Substitute Fuels Protocol, The Environment Agency, November
2001. Back
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