Memorandum submitted by the Environmental
Services Association
1. ESA is the sectoral trade association
for the United Kingdom's regulated waste and secondary resource
management industry, a sector contributing £9 billion
per annum to GDP. Our Members recover more of the value contained
in the UK's waste—for example, household recycling has quintupled
in the last decade—whilst protecting the environment and
human health.
2. It is perhaps symptomatic of difficulties
faced by our sector that, although we produce one third of the
UK's renewable electricity, our sector has not been invited to
appear before the Committee.
3. Energy from waste is an essential component
of modern waste management infrastructure. More recovery of energy
from waste is compatible with further increases in recycling and,
as well as achieving the secondary, but important objective of
diversion from landfill, it offers an indigenous and secure source
of supply of energy. It is also—as evidenced by repeated
official studies and as below stated—very safe and emissions
from our Members' regulated infrastructure are particularly strictly
regulated under EU law. HMG's international commitments on reduction
of carbon emissions rely in part on energy from waste.
4. An effective and efficient planning process
is required to achieve greater economic and environmental sustainability
and to enable the UK to meet its legal duties resulting from EU
laws on waste management, which in practice require more recycling
of materials and recovery of energy from waste.
5. Defra predicts that £11 billion
investment in new waste management capacity is needed by 2020 to
comply with the relevant EU laws predating the 2008 Waste
Framework Directive, a law which may necessitate even more investment.
Our sector is therefore effectively asked to invest £1 billion
every year for more than a decade in new infrastructure.
6. Obtaining planning permission remains
the single biggest barrier to the timely delivery of new waste
management infrastructure. Of the eight Energy from Waste (EfW)
planning applications submitted by ESA's largest Members over
the last three years, six have been refused consent: often against
the recommendations of local authority officers.
7. While the Planning Act has in a number
of respects fallen some way short of the modernisation of the
planning regime the Government had intimated would be forthcoming
for our sector in the current Parliament, in principle we welcome
the concept of a robust Energy National Policy Statement providing
a coherent and practical planning policy framework.
THRESHOLDS
8. We may in the light of practical experience
invite the Secretary of State to propose an Amending Order to
clarify and amend thresholds in the Planning Act for qualifying
waste management infrastructure which currently, contrary to some
political preferences, discriminate against meritorious EfW facilities
not large enough to meet the 50MW threshold. (Also, while not
directly relevant to the Committee, the threshold for hazardous
waste infrastructure is too low: imposing the expensive IPC process
on small items of such infrastructure would render them wholly
uneconomic.) Only one of the UK's existing 29 EfW facilities
would have met the Section 15 threshold, although five potential
schemes do exceed 50MW. While HMG is promoting Anaerobic Digestion
as a waste treatment, no such facility would approach the 50MW
threshold and neither would advanced conversion technologies such
as gasification and pyrolysis, in part as a result of the lower
energy generating efficiencies of these alternatives.
MATERIAL CONSIDERATION
9. It might be helpful if HMG provided more
guidance to local authorities on the practical application of
1.2.1 of EN-1 and 1.2.4 of EN-3.
DEMONSTRATING NEED
10. ESA welcomes HMG's acknowledgment that
waste combustion plants should be considered renewable energy
projects and that the IPC should begin its assessment of relevant
applications on the basis that need had already been demonstrated.
However, we would welcome the policy being made more robust, with
specific recognition of waste's potential to provide a more reliable
electricity base load than other more intermittent renewable generation
technologies. The waste sector remains the largest generator of
renewable electricity in the UK despite the supposed installed
generating capacity of onshore wind being more than twice as great
as that of waste-fuelled technologies.
HEALTH
11. The IPC should note that the Waste Strategy
2007 (paragraph 22 of chapter 5) rebuts objections to
EfW that cite the precautionary principle: research carried
out to date shows no credible evidence of adverse health outcomes
for those living near incinerators. A recent decision by the
Secretary of State has also been consistent with this.
12. In 2009, the Health Protection Agency
(HPA) revised its guidance on the health effects of EfW, and reinforced
its previous position that there are no significant health effects
associated with the emissions from such facilities.
3.4.3: EN-1
13. The reference in the third bullet point
to biomass is of limited relevance as no infrastructure—other
than EfW facilities—combusting waste biomass would meet
the 50MW threshold. In the fourth bullet point, we believe the
"principal purpose of burning waste" is not as stated
but is "to recover energy".
4.6.6: EN-1
14. Opportunities for development of waste
fired CHP plants remain constrained by un-coordinated public policy.
However, the IPC should note that an electricity generation-only
facility can in some circumstances offer net environmental benefits
over CHP, as evidenced by the EU's Waste Framework Directive which
considers electricity generation to be more valuable than heat
when considering the benefits of waste fired CHP.
4.29: EN-1
15. The final sentence of 4.29.5 is
not an accurate or adequate summary of the waste hierarchy set
out in 4.29.2.
ENERGY HIERARCHY
16. We note the oral evidence provided by
the Institution of Civil Engineers. Their support for a hierarchy
allowing the IPC to prioritise renewable energy development over
more carbon intensive generation of energy could merit consideration
when relevant sectors have made further progress on harmonising
metrics. ESA launched a major initiative in 2009 giving more
transparency to the carbon footprint of Members' various operations.
January 2010
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