Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence

Memorandum submitted by Innogy

  1.  Innogy is a leading UK energy company. We generate electricity and supply gas and electricity through our retail business, npower. We operate and manage our flexible portfolio of power stations, run our own trading business and are developing innovative energy-related technologies. We are also market leaders in renewable energy production. Innogy takes its responsibility towards the environment very seriously: we use best practice to manage our waste and endeavour to adopt waste minimisation practices wherever practicable. We welcome the opportunity to contribute to the Committee's inquiry.

  2.  Although we have no substantive concerns about the structure of the waste hierarchy as it stands I would like to draw your attention to two specific issues, which we perceive as being of particular relevance to the Committee's deliberations. These are the disposal of Pulverised Fuel Ash (PFA) from coal burning in power station operations and the incineration of recovered fuel oils (RFOs) at power stations.


  3.  At present PFA is not classified as a waste if it is used as a product in the construction sector under strict regulatory controls. However based on discussions with the Environment Agency we are aware that the Agency is considering reclassifying PFA as a waste and, as a consequence, including it in the hierarchy. For some thirty years the electricity industry has sold the ash from coal fired power stations to the construction industry, and currently three millions tonnes, of 60% of the UK total production, of this valuable resource is sold annually. Many power stations have invested in plant to facilitate the sales of PFA to a range of applications. There is no record of any adverse environmental effect from the use of PFA in construction.

  4.  Reclassifying PFA used as a by-product as a waste will almost certainly destroy the long-established markets for the material because of the stigma of designation as a waste and the requirement to comply with the full range of waste management regulations. This is likely to confine a large proportion (if not all) of the material to the bottom of the hierarchy—landfill. This is clearly in conflict with the Government's stated waste hierarchy, which seeks to utilise by products rather than send them to landfill. There is no other option, as any other possible activities do not, we believe, meet the definitions of recycling or recovery and the material cannot be used as a fuel. However, by allowing the current arrangements to continue, and letting the Aggregates Levy run its course, more material will be utilised and removed from the hierarchy completely.

  5.  Removing barriers to the use of PFA as a secondary aggregate (ie not calling it a waste) also provides an opportunity to actively market PFA that has already been landfilled and, therefore, correctly labelled as waste. Excavated material has essentially the same properties as the ash produced at power stations and so it too should be regarded as a by-product immediately it becomes available. Using this material moves it up the hierarchy from landfill to the second rung from the top, re-use of waste.

  6.  Furthermore, reclassification of PFA as a waste would put a burden on the construction sector to find alternative sources of aggregates from potentially primary mineral sources with associated impact on the environment. One might anticipate then an increase in quarrying and dredging of primary aggregates.

  7.  There is clearly some inconsistency across European countries in the treatment of PFA and the interpretation of EU legislation. Dutch legislation for example requires that producers of PFA give a specific and stated use for the product. It is not classified as a waste. Utilisation of PFA is encouraged across Europe and if transport costs are not prohibitive, we would welcome the opportunity to sell ash into European markets. We are concerned that if the use of PFA were prohibited in the UK it would put unwarranted barriers in the way of such opportunities.

  8.  In summary we believe that there is no logical argument for reclassifying PFA destined for use in the construction sector as a waste. Indeed such reclassification would run counter to the Government's waste strategy. It would also increase the use of landfill, the quarrying and dredging of primary aggregates, increase costs (landfill and replacement materials) and lead to an increase in carbon dioxide emissions due to transport to disposal sites and processing costs for replacement materials.


  9.  Our second concern relates to Recovered Fuel Oils. These have recently been classified as a hazardous waste and at present much of this oil is used in power stations as a source of fuel. Indeed RFO often displaces heavy fuel oil as its environmentally more benign than heavy fuel oil. Energy recovery is a positive use for waste oil, and is economical for power generation. However the implementation of the Waste Incineration Directive is likely to prevent combustion of RFO in power stations from 2006.

  10.  We understand that the European Commission (EC) would like to see the Waste Oils Directive implemented such that recycling is encouraged ie with Member States encouraging collection and re-use. At present the UK is very good at collection, (in fact it has the highest collection rate in Europe at 86%) but all collected waste oil in the UK is re-used by "recovering energy" through combustion. We are concerned that preventing RFO being combusted in power stations in the interests of "encouraging recycling or re-use" will lead to a reduction in the quantity of oil collected because any move to reduce combustion of RFO is likely to lead in a reduction of the market price. If this happens then potential, users will be expected to pay for collection of waste oils in the future, which could result in increased illegal tipping. In addition it could result in increased cost for producers of waste oil, increased costs for power generation, and increased cost of disposal.

  11.  The main alternative for the disposal of this valuable fuel would be incineration since it cannot be landfilled. There is currently no market for recycled waste oil, and indeed there are no recycling facilities in the UK as far as we are aware. Therefore we believe that burning waste oil, under strict environmental regulations, with the production of energy is clearly the best practice in terms of dealing with this waste and is consistent with the Government's waste hierarchy strategy.


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