Memorandum submitted by Environmental
Recycling Systems (Waste 64)
EXECUTIVE SUMMARY
1. This response is from Environmental Recycling
Systems (EVRS). EVRS has a unique technology for dealing with
residual waste, developed in the UK over the last six years. EVRS
is one of the 37 new technologies listed in the "Defra Waste
New Technologies Demonstrator—Programme Catalogue of Applications—2007
Update" (NTDP) (1). Of these projects, only nine were offered
funding, leaving 28 to their own devices. We are told that there
may have been a further group, perhaps as many as 60, excluded
for lack of ownership of the originality by the submitter.
2. The industry needs a choice of technologies
to cope with a range of arisings. No one size, or one technology
can fit all requirements, as local needs vary. We have identified
many potential buyers of our process, all of whom rightly say
that they cannot proceed without seeing a full size demonstrator
plant delivering on our claims. We are in no doubt that this applies
to the other NTDP applicants as well.
3. In our own case, we claim that our process
can achieve almost total diversion from landfills of non-hazardous
residual waste arisings. These can arise from Construction, Demolition
and Excavation recycling, Commerce, Industry, Retail, and all
other like non-hazardous residues which are predominantly organic
(cellulosic). Using our process of "Thermally Induced Chemical
Transformation" (TICT), we recover pure Cellulose and some
Ethanol. This is a resource recovery technology to obtain new
materials for reuse. It is anaerobic, using steam at 165°C
and 7 Atmospheres (100 psi). We ensure that the process has no
discharges to air, to land or to water, by hermetically sealing
the plant, and by building it into ISO shipping containers. There
will be no odour (being sealed), and little noise. Air and process
water are to be extracted and cleaned in separate units, again
recovering the resources therein. The design is fully scalable,
from ½ T/Hr to 20 T/Hr and multiples thereof, enabling it
to address the proximity principle, by for example siting the
plant co-located with a producer of waste, such as a factory,
school or housing estate. There is the potential to process other
waste streams such as sludges and slurries, make the plant relocatable,
and even process material mined from existing landfills, as is
now being suggested (by Peter Jones OBE, currently the Mayor of
London's representative on the London Waste Strategy Board).
4. The process has been extensively demonstrated
with a wide variety of inputs including board, card, food waste,
both cooked and uncooked, paper, sawdust, straw, wood, etc. and
has been shown to produce consistent results. It has been peer
reviewed. (2). The process deals with co-mingled waste, separates
inorganic material from the organics stream, and cleans materials
such as plastic food wrappers, recovering both the cellulosic
material and the plastics. As such therefore, source separation
becomes un-necessary, which in our view could eliminate the cost
of tactics such as alternate weekly collections, and multiple
bins.
5. Our Research and Development was funded
entirely by ourselves. We have a small working Product Evaluation
and Test (PET) Plant, and have been seeking £1.2 million
to build a suitable continuous demonstrator plant with 100 T/week
capacity, but so far, have been unsuccessful. Nevertheless, we
have a suitable site, waste stream and tremendous supplier support.
6. We believe that many of the others listed
in the catalogue have now been forced to withdraw, their technologies
being lost to the industry.
7. Had our technology been funded under
the demonstrator programme in 2006, the choice would thereby have
been increased. We have an unnecessary delay of two or even three
years in bringing our technology to the marketplace. In our view,
this denies the choice at a time when it is greatly needed.
INTRODUCTION AND
BACKGROUND
1. EVRS has studied the responses submitted
by the Environmental Services Association (ESA) and by the British
Metals Recycling Association (BMRA), and to a very large degree,
adopts the relevant points as submitted by both these associations.
2. It is clear that the industry needs choice.
We would like our process to be available for consideration by
those who have to process waste. Wider choice will be denied them
unless we have a suitable demonstrator plant—the Defra foreword
by Peter Jones OBE makes that very clear.
RESPONSES TO
THE SPECIFIC
POINTS IN
THE WASTE
STRATEGY EXAMINATION
BRIEF
1. How the policies proposed will be implemented
Our process, like that described by BMRA members,
and others like us, can produce material which is fully recovered
for re-use. All this material is marketable as such and has a
value. The regulations must therefore ensure that all materials
fully recovered which have a ready market are declassified from
the definition of "waste". Failure to do so will deny
the market-place sources of valuable material (at the time of
writing, we project that our fibre product, "Zystur TM" will sell for some £400 per Tonne). Our "Zystur
TM" fibre is an inert, sterile
material potentially capable of incorporation into engineered
plastics for use as building material and insulation, thereby
turning Waste to Worth. This does for example displace wood flour
which is variable and biologically active, with a fibre which
is consistent and sterile, allowing production of a far better
grade of new weatherproof "plastic wood". This also
can be recycled through the plant at the end of its useful life.
Without the declassification of such a recovered
material from the classification of waste, there will be no international
trade for our outputs—exactly the position that the BMRA
submits.
2. The role for and implementation of regulations,
and their enforcement
Like the ESA, we support effective regulation, and
heavy penalties for those who operate illegally. This also requires
that a proportionally light hand is used in respect of well run
and legally operated businesses. We have advocated that individuals,
not amorphous corporate bodies, should be trained and regulated.
If the gold standard for plumbing and heating engineers is to
be "Corgi"®
registered, why not a mirror system for the waste industry, which
already has a lead body, the Chartered Institution of Wastes Management
(CIWM) which is very active in training? This removes deniability,
and provides full accountability.
3. The classification of waste
This issue is of great concern to us, as only if
our outputs cease to be classified as waste do we have the attractiveness
of a model which returns value by producing saleable outputs,
as well as landfill diversion. We produce new material, hence
achieve re-use rather than just recycling, thereby moving us up
the waste hierarchy.
4. The proposal for financial incentives
to increase household waste prevention and recycling
Given that household waste may be a headline but
is only a small part of the total waste stream, (perhaps 10%)
we believe money spent here is disproportionate, and could be
much better spent elsewhere, such as funding new technologies,
of which ours is one.
5. The role of composting
Composting on a large scale is potentially fraught
with problems of segregation and safe re-use, and when used purely
as a means of disposal is in our view a very poor investment.
Newer technologies, ours included, have the potential to return
far better value. We would at least like to be able to make our
case, but are denied access to the key funds that would make this
possible.
6. The Government's approach to waste minimisation
We see expenditure in this area as misdirected, when
waste, and growth in arisings are facts of life, particularly
when economies are in a growth phase. Good engineering design
at the manufacturing stage should allow for better separation
when recycling, leading to more recovery. One problem for example
is that some soft drinks manufacturers currently use cap security
rings which do not detach from the bottle, thereby contaminating
the material of the bottle, when recycled. Another is the use
of plastic tapes and label holders on cardboard boxes causing
excessive contamination. We have been told anecdotally of Councils
sending loads of cardboard to mills for recycling, having it rejected
for this reason, and on its return, counting it again as new arisings!
We agree with the ESA that this is no substitute for investment
in infrastructure, which must surely be the highest of all priorities.
7. The potential for the proposals to tackle
the UK's contribution to Climate Change
We support the ESA's position.
8. The promotion of anaerobic digestion for
agriculture and food waste
As we consider that this process is a distraction
from the newer technologies of which ours is one, we are against
this being singled out for specific support. Like the ESA, we
believe that the choice should be the widest possible, so that
market forces can make the best choice for each particular objective.
We therefore oppose this one technology being promoted over others,
irrespective of its efficacy.
9. The adequacy of the existing infrastructure,
such as energy from waste (EfW) facilities with heat recovery;
the UK's capacity to process materials collected for recycling;
and the potential for Government action to encourage the most
efficient novel technologies
a) Insofar as infrastructure goes, landfill is
the wasteful placing of valuable resources largely out of reach,
and the despoiling of our rural heritage, putting great pressure
on land for essential housing, and this is our legacy. We inherited
a green and pleasant land. We believe that as custodians of our
countryside we have a duty to pass it on to our children and grandchildren
in better condition than were received it, not worse.
b) We believe that Energy from Waste is an over-centralised
technology which destroys valuable materials, returning very little
value. It also opposes the proximity principle. It is however
a large piece of capital investment of value to those who acquire
it. Sheer scale suggests that these may be made into dinosaurs
sooner than expected as it becomes vital to implement the proximity
principle which will reduce carbon footprints and match local
needs.
c) We believe that the UK as a whole has
the will to collect and process materials. What is needed is investment
into the infrastructure, as spelt out in the Institution of Civil
Engineers "State of the Nation" review in 2004 (3).
d) We consider that the potential for Government
action to encourage the most efficient novel technologies is vast,
and the investments sought, comparatively with say PFI credits
for an EfW plant, are very small indeed. If for example the original
£30 million Defra New Technologies fund had been reasonably
evenly distributed, with supplier contributions and equity investment
to match, we would already have our demonstrator plant in place,
and not still be seeking funding.
e) The BMRA submission has highlighted the
need to address Automotive Shredder Residue (ASR). We believe
that our process will deal effectively with this arisings stream,
recovering the fibre, metals and plastics as discrete streams.
Trialling this will require funds that we do not have.
f) The Defra submission supplement, at para.
4.19, refers to funding for new technologies. We have been unable
to access this, the original £30 million fund being exhausted
in 2005, and no new funds having been added since then. The Defra
position was confirmed to EVRS today (25 November 2008) by John
Burns, the Defra Programme Director of the Waste Implementation
Programme (4), who said:
"The initial funding of £30 million
(in 2005) has not been supplemented.
There are no new funds and what is unspent is
committed.
There is no scope for new technologies to enter
the programme."
g) We therefore consider that further investment
into new technologies is vitally important, especially where the
process can be operated to deliver a significant return on investment.
Such a strategy would reduce the burden on the taxpayer whilst
generating a valuable new resource and income from sales of outputs.
References
(1) The "Defra Waste New Technologies Demonstrator—Programme
Catalogue of Applications—2007 Update" (The EVRS technology
is the last entry)
http://www.urbanmines.org.uk/assets/files/n/newtechnologiescatalogue2007_635.pdf
(2) To view the article on our EVRS "Zero-Bury"
process in the September 2008 issue of the Journal of the Chartered
Institution of Wastes Management, go to:
http://www.evrs.co.uk/vision/osment_EVRS_new_tech.pdf
(3) The Institution of Civil Engineers "State
of the Nation" review in 2004
http://www.ice.org.uk/downloads//SoN2004_Waste_Briefing_Document.pdf
(4) The Waste Implementation Programme:
http://www.publicservice.co.uk/pdf/central_gov/issue11/CG11_sup%206002%20JohnBurns%20ATL.pdf
Environmental Recycling Systems
November 2008
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