APPENDIX 14
Letter and memorandum to the Clerk of
the Committee from the Environmental Services Association
The Environmental Services Association (ESA)
is the sectoral trade association representing the UK's waste
and secondary resource management industry, a sector contributing
more than £5.0 billion to the UK economy (about 0.5% GDP).
Our Members want to build our industry's future on managing more
waste as a resource by returning more of the materials and energy
contained in waste back into the productive economy.
ESA welcomes this opportunity to offer evidence.
We are primarily concerned with Chapter 4 of the White Paper covering
low carbon generation and our comments are focussed on how best
to accelerate the UK's rate of renewable energy generation capacity.
Memorandum from the Environmental Services
Association
EXECUTIVE SUMMARY
— The UK faces major environmental
challenges: it is obliged by national and international agreements
to change the way it generates energy and manages waste.
— The UK already lags behind other
EU countries in the generation of renewable energy: if the Government
is not to fall behind even further, action is needed now.
— The Energy White Paper does not grasp
the opportunity to secure a more sustainable long-term supply
of energy for the UK by providing the necessary impetus to encourage
higher levels of renewable energy generation from all available
sources.
— The UK does not appear to be putting
policies in place to deliver the potential contribution of renewable
energy from municipal solid waste. The Government has missed a
significant opportunity to link energy policy and waste management
policy to secure greater extraction of the energy contained within
waste.
INTRODUCTION
1. The Royal Commission on Environmental
Pollution concluded that the UK needed to reduce its carbon dioxide
emissions by 60% by 2050 to avoid environmental catastrophe. In
this context it would be reasonable to expect the Energy White
Paper to put in place a framework to maximise the use of all possible
low carbon energy sources.
2. However, the Government has continued
to ignore the framework provided by the European Directive 2001/77/EC
on promoting electricity from renewable sources and has opted
for a selective approach without any apparent consideration of
tools such as life cycle analysis or Best Practicable Environmental
Option.
3. Article 2 of this Directive provides:
"For the purposes of this Directive, the
following definitions shall apply:
a. `renewable energy sources' shall mean
renewable non-fossil energy sources (wind, solar, geothermal,
wave, tidal, hydropower, biomass, landfill gas, sewage treatment
plant gas and biogases); and
b. `biomass' shall mean the biodegradable
fraction of products, waste and residues from agriculture (including
vegetal and animal substances), forestry and related industries,
as well as the biodegradable fraction of industrial and municipal
waste."
4. Nonetheless, Government has decided generation
of renewable energy from the incineration of mixed waste does
not count towards the UK's 10% renewable energy target by 2010
and is ineligible for support under the Renewables Obligation.
We believe the Government should include this source of energy
for the purposes of meeting official renewable energy targets,
in line with Directive 2001/77/EC.
A GREENER WHITE
PAPER
(a) Connecting Waste and Energy Policy
5. Currently, 48% of the UK's renewable
energy is derived from municipal solid waste. 27% is generated
from landfill gas (installed capacity is projected to increase
by 65% by 2010), and 21% is generated by combusting waste.
6. Implementation of the Landfill Directive-requiring
the diversion of large amounts of waste from landfill to other
treatment options-provides significant potential to increase renewable
energy capacity by thermal treatment of waste using both conventional
technologies and emerging technologies such as gasification and
pyrolysis.
7. ESA is disappointed that even though
the PIU report "Making more with less"[34]
identified climate change and waste generation as the first and
second environmental priorities for Government; the Energy White
Paper fails to connect these two vitally important issues.
8. The UK lags far behind other EU Member
States in its installed renewables capacity. The UK's share of
renewables, based on gross inland consumption, was only 1.1% for
2000, compared to 30.7% for Sweden, 23.9% for Finland and 23.2%
for Austria[35]
9. Likewise, progress in deploying energy
from waste capacity in the UK has also been noticeably slower
than in other Member States: whilst the UK extracts energy from
8% of its municipal waste, Denmark derives energy from 59% of
its waste and the Netherlands 42%.
10. Furthermore, other Member States make
more provision for district heating infrastructure than the UK.
Denmark provides the economic and regulatory framework to make
it viable for energy from waste facilities to supply heat and
electricity to local communities: 57% of municipal waste incinerated
is treated in CHP plants compared to 17% in the United Kingdom.
11. Energy from waste facilities provide
an important opportunity for the generation of good quality CHP.
Whilst the recent announcement of Climate Change Levy exemptions
for energy generated by CHP facilities is welcome, further incentives
for the development of CHP are urgently required.
12. The Government must overcome a number
of obstacles in order to increase CHP in the UK:
— there is limited installed district
heating infrastructure in the UK;
— obtaining the necessary planning
permission and laying the infrastructure can be difficult and
costly; and
— plant needs to be situated close
to new high-density housing developments or industrial parks where
the necessary infrastructure can be installed in the construction
phase to accommodate heating schemes.
13. For CHP to work, end users need to be
connected. Building regulations and planning guidance should reflect
the need to accommodate CHP schemes where they are technically
feasible and economically viable.
(b) Financing Green Energy
14. New infrastructure can only be delivered
and operated if it is economically viable. The UK renewable energy
market is characterised by low certainty and high risk. Financial
institutions can only release capital if they are confident that
the investment is sufficiently likely to generate a reasonable
return.
15. The Energy White Paper does not provide
an adequate financial framework for accelerating the deployment
of new renewable capacity. The Government must:
— bring forward the review of the Renewables
Obligation to no later than 2004-05 so that long term investment
decisions can be based on the certainty provided by long-term
Government commitment; and
— set the percentages for the Renewables
Obligation on a 10-year rolling basis to provide certainty each
year on the proportion of renewable capacity that will be obligated
in 10 years time.
(c) Can the Planning System Cope?
16. The White Paper recognises that in order
for the UK to meet the Government's 10% renewable energy target,
an additional 1,250 MW of renewable energy capacity will need
to be installed every year until 2010, against a current total
installed capacity of only 1,200 MW. The challenge in achieving
this is obvious, and even greater if the Government intends to
achieve a 20% target by 2020.
17. Government targets must be supported
by appropriate policies to enable their delivery. If the Government
is to set itself a target on the generation of renewable energy
then it is incumbent on the Government as a whole to deliver on
the target. Renewable energy targets must be supported by appropriate
policy across the Government.
18. The review of national planning policy
guidance note PPG22 must strengthen existing planning guidance
for renewable energy projects. Further reform of the system is
required to speed up the assessment of planning applications and
to achieve greater certainty in the delivery of decisions.
19. Review of PPG22 on renewable energy
should be coordinated with review of PPG10 on waste management
in order to coordinate energy and waste planning policies.
(d) Connecting End Users
20. If the UK's energy policy is to move
forward, the Government must ensure the availability of appropriate
and cost-effective grid connections. It is well known that a more
decentralised energy supply system will require modifications
to the design and operation of the grid.
21. The availability of suitable and affordable
grid connections is of particular importance with regard to the
planned introduction of BETTA by April 2005, whereby a single
set of electricity trading rules, connection policies and transmission
trading costs will apply throughout the UK.
April 2003
34 Resource Productivity Making more with less'
Performance and Innovation Unit, 2001. Back
35
Statistical Office of the European Union. Back
| 
