Memorandum submitted by the Environmental Services Association (NPS 22)

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