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 hierarchylandfill.
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
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