The sensible overall conclusion is that this is not a proposal which on its own merits deserves to succeed. It amounts to a short term gain in terms of achieving targets at the cost of long term pain for the receiving environment and for the communities affected by the decision. This is indeed a case where “the folks” and their elected representatives have reached the right conclusion about what is best for the places in which they live. They deserve to have that decision respected by the Secretary of State. For all these reasons the inspectors are invited to recommend that the appeal is dismissed.

Let’s hope our Eric is listening!

Local campaigners are aware that there is still a fair way to go before they can finally put this application to bed, and they have kindly provided UKWIN with an approximate timetable of what happens next based on similar previous inquiry outcomes.

• Environment Agency Permitting Consultation – 11th August 2010 (consultation closes followed by decision)
• Planning Inspector’s Report – October 2010
• Secretary of State’s Decision – December 2010 (decisions can take as long as 6 months or even a year, but they tend to take 2 to 4 months)
• Challenge Stage – January – February 2011 (potential opportunity to challenge if the decision does not go our way or for Viridor if they are not happy)

In the meantime Ardley Against Incinerator will be working towards the second planning application hearing by Oxfordshire County Council’s Planning Committee, which is expected sometime in September or October 2010.

According to one of Ardley Against Incinerator’s leading lights:
If there is an additional piece of good news from the last three weeks, it is the amount of information and advice we have been able to pick up that will make fighting the second application a little easier.

The Ardley Against Incinerator group sends a big “thank you” to all of their supporters, including the following parties, for their dedication and support since their first ever meeting back in July 2008: Bucknell & Middleton Stoney Parish Councils, Bicester Print, Cherwell District Council, CPRE, FOE Oxfordshire, B430 Traffic Group, Planing Aid, Sam @ NewsQuest, SAVI, SCAI, Tusmore Estate and Weston Front.

Ardley Against Incinerator is a not for profit voluntary group formed by concerned local residents and business campaigning against the proposed development by Oxfordshire County Council and Viridor Waste Management of a 300,000 tonne industrial incineration plant at Ardley Fields Farm.

To keep up to date with the Ardley Against Incinerator group visit their website at: http://www.ardleyagainstincinerator.co.uk/

And there continues to be much to track in Oxfordshire, including Oxfordshire County Council’s recent decision to sign a contract with Viridor for, would you believe it, an incinerator at Ardley.

This story has been covered by both LetsRecycle and BBC Oxford.

And plans are expected in August for an MBT plant at the site at Sutton Courtenay (near Didcot in Oxfordshire) previously subject to a failed planning application for an incinerator. See Waste incinerator bid for Sutton Courtenay withdrawn.

The presentation was delivered on 14th July 2010 to the Associate Parliamentary Sustainable Resource Group (APSRG) at their ‘Priorities for Parliament: Sustainable Resources for a Sustainable Society’ event.

Dr Warhurst called on the new Government to scrap PFI investment because it leads to “expensive, inflexible incineration”, which he described as a “dying” technology.

We’re wasting money on the wrong infrastructure. We have a situation at the moment where many councils are wasting billions building expensive, inflexible and climate-damaging incineration. It’s a technology that’s dying, but is taking rather a long time to die.

According to the MRW article, Warhurst called for a more cost-effective method of waste infrastructure finance, which would not lead to the construction of incineration plants.

Speaking on behalf of Friends of the Earth, he said:

In our view, PFIs should be abandoned because they’re a very expensive way of building things. And the contracts should be much shorter, say, 5-10 years, because the right infrastructure can be built with short contracts, such as anaerobic digestion plants, residual waste, composting and separation

The MRW article goes on to describe how these comments were echoed by Local Government Association programme director for environment and planning Martin Wheatley, who called for a “radical look at new forms of relationship between councils and the private sector”.

Download Dr Warhurst’s APSRG presentation [PDF]

The Agenda includes:

A Strategy towards 2020 Zero Waste, the business case will be presented by Peter Jones. Peter is the chair of a specialist group looking at a Zero Waste economy for Advantage West Midlands. He is former director of Biffa Waste Services and an advisor on zero waste for the Scottish Parliament and the Greater London Assembly. He will talk about how waste management and the recycling sector is the next significant opportunity for businesses, creating jobs and putting the region at the very heart of the governments green low carbon revolution. Ralph Hepworth, of the National Industrial Symbiosis Programme will also contribute.

Participants will also be treated to an introduction to the 2020 Zero Waste Project Network by Jane Green, of Friends of the Earth. A meeting to initiate a ‘2020 Zero Waste Project Network’ was held in February with Professor Paul Connett from St Lawrence University, New York, an international specialist and campaigner for Zero Waste. Draft ‘aims’ for a ZW Network were discussed. This project would aim to establish a central hub, with office facilities and a team to develop this initiative, as well as a network of volunteers. It would be complemented by a virtual network linking relevant partners and projects, locally and globally, from business, public sector and community.

According to Jane Green:

The establishment of a 2020 Zero Waste Network would seek to establish an initial ‘Zero Waste’ Centre by integrating academic and technical expertise in one place.

A 2020 ZW working group will be formed that would involve all interested parties to further the 2020 ZW initiative – in particular to consider possible funding and a Waste Conference for review / consultation with all stakeholders. The working group would also be tasked with establishing the terms and responsibilities for the network and frequency of meetings.

An historic decision was taken by Swansea City Council to bar future contracts with Veolia on the grounds of its illegal activities in the West Bank.

Swansea City Council approved the following resolution on Thursday June 17th 2010:

The UN not only does not recognise Israel’s annexation and occupation of East Jerusalem, but has repeatedly stated its view that the Israeli settlements in East Jerusalem and the West Bank contravene international law, and it has demanded that Israeli settlement activities and occupation should not be supported. The international trading company, Veolia, is a leading partner in a consortium seeking to build a light railway system linking Israel to illegal settlements in occupied East Jerusalem, a project that clearly not only contravenes UN demands but is in contravention of international law.

This Council therefore calls on the Leader & Chief Executive not to sign or allow to be signed any new contracts or renewal of any existing contracts with Veolia or any other company in breach of international law, so long as to do so would not be in breach of any relevant legislation.

According to the blog article, Veolia currently has contracts with the authority for local bus, park & ride to the tune of £699k per annum and home school to the tune of £238k per annum.

The passing of the resolution was important in its own right, but Swansea Action for Palestine have since discovered that this is the first resolution of its kind to have been passed by any UK authority, in that it makes explicit its reasons for ruling out any future contracts with Veolia. Other authorities have discontinued contracts with Veolia, but have not specified this reason. Swansea City Council is therefore leading the way with what is now seen as a landmark decision.

The resolution was put to the Council as the result of a campaign, in the course of which, all 72 councillors were mailed with details of Veolia’s illegal activities. Swansea Action for Palestine were gratified with the level of cross part support for some kind of action to be taken and have since been in regular contact with councillors from nearly all parties who are actively pursuing the issue.

Swansea now leads a growing number of cities ready to take a moral stand against international lawbreakers. The list already includes Dublin, Stockholm and Melbourne and within the UK moves are already being made which would mean that other authorities follow Swansea’s example.

A controversial private finance initiative project (PFI) to replace the Whitley incinerator looks set to be scrapped. A Freedom of Information request by the Telegraph has found that cash-strapped local councils have already forked out more than £1.7 million on the plan, including hundreds of thousands on external consultants.

Furious councillors in Coventry and Warwickshire are demanding an immediate stop to the project, which they say is draining £22,000 a week from the public purse.

Coventry city councillor Dave Nellist (Socialist, St Michaels) has fought the PFI plan from the start. He is quoted in the Telegraph article saying:

This must be stopped. Our children’s services budget is suffering a £2.3 million hit next month, so finding we’ve spent this amount on consultants and accounts when our kids are running short of children’s centres and youth workers ­it just cannot be right.

According to the article, more than £1.2 million has been spent on external advisers over the past three years, with the costs met by Coventry City Council (£645,000), Warwickshire County Council (£690,000) and Solihull Borough Council (£403,000).

As has previously been reported, shortly after taking control of the city council in May, Labour leader John Mutton cast doubt on the PFI plan, saying he wanted to refurbish the current plant rather than build a new one, whilst Coventry’s Conservatives, who had spearheaded the PFI plan before losing control of the city council, wrote to George Osborne urging him to pull the plug.

The article goes on to quote other politicians, such as Warwickshire councillor John Whitehouse (Lib Dem, Kenilworth Abbey) who “has tried for months to put a stop to the scheme”:

I’m sorry to say I’m not surprised by these figures. It has been shown to be a massive waste of money.

Councillor Whitehouse says this year’s county council budget included a further £400,000 for the project at a time when Warwickshire’s adult services are facing “swingeing cuts”, adding:

If that spend hadn’t been necessary the cuts would not have had to have been so steep.

And even John Daly, director of Project Transform, the team driving the PFI plan, is quoted as saying:

Looking back we could say maybe it wasn’t a good use of money, but at the time we spent it we were working to a plan approved by the three councils. Until we get formal notification from the councils we must just carry on.

Under the UK’s system for promoting renewable energy technologies – the Renewables Obligation legislation [1] – subsidies guaranteed for years [2] are granted via Renewables Obligation Certificates (ROCs) and are readily available for energy generation that is far from efficient and, in particular for forms of incineration, waste the majority of the energy which is heat [3].

Waste wood often contains chemical preservatives or is coated with paint, while composite woods like melamine or MDF include chemical glues and coatings.  Modern decking may contain 30% plastic.

Incinerating waste wood receives excessive subsidies because pyrolysis and gasification are classed as “Advanced Conversion Technologies” with no conditions on efficiency or nasty wastes.  Both technologies are defined as ‘incineration’ under the Waste Incineration Directive.

So-called “advanced” gasification or pyrolysis may attract double ROCs for each unit of electricity (although some facilities are experiencing difficulties securing ROCs from the regulator OFGEM), this for gasification or pyrolysis processes that produce very low quality gas and then burn it, in a two stage incineration process.

In numerical terms, pyrolysis qualifies for double ROCs if the gas calorific value exceeds 4 MJ/m3, whereas best technology reaches 11 MJ/m3 (natural gas for comparison is about 70 MJ/m3 ).

The lucrative subsidies are the reason for the rash of planning applications for wood-burners.  One example is the Hudol pilot plant at Rhymney (www.hudol.co.uk) and a test plant at Tythegston (Bridgend) that over ten years never worked well with domestic wastes, transgressing NOx and CO limits on several occasions. “Technical problems have prevented the plant from operating to its full potential” they say, and Bridgend Council granted permission last year for autoclaves to be substituted, working on steam from combustion of the output fibre.

Like many such schemes, Hudol’s technology was on the way to fail until a small consultancy called Sedgwick Associates took it on under a “Sunrise Renewables” label.  Their business model aims to attract city finance for docks-based plants, able to import wood wastes as well as take them from the locality.  Sedgwick told the Inquiry into a proposal for a plant in Barry/S. Wales in early June that they have won three permits, in Barrow-in-Furness, Sunderland and Hull [4].

Barry & Vale FoE were their main opponents at the Inquiry and found that Sedgwick have little knowledge of the engineering and the waste wood businesses, and buy in consultants without specific knowledge.  They did not know wood composites contain plastics, claimed the ash would not be hazardous waste if the input wood was ‘non-hazardous’, and produced a mass-flow diagram that they couldn’t explain and was clearly incomplete.  Their claims to CHP were shown up when they hadn’t thought to cope with daily and seasonal variations in demand, or to a back-up heat supply when the incinerator is down.

It seems they had succeeded in England without EIA, but a FoE objection caused trouble at the Welsh government office. The Welsh officials first decided it’s an EIA ‘Schedule 1’ project, as a waste disposal installation handling more than 100 tonnes/day (there’s a ruling that “disposal” covers incinerators that recover energy and/or materials).  Heavy lobbying by the company (uncovered by a Freedom of Information request) got them to reverse that and declare it’s not an EIA project.  They are clearly worried about their contortions – in pursuit of government policy to expand biomass power – and FoE plan to take it to the European Commission.

The consultants made a lot of government policy on biomass, including the Welsh plans for 50% of biomass to be imported, so as to claim that Welsh energy will be all renewable.  This is problematic because the Welsh government also claims to be going for “high efficiency” CHP, but no-one sees the way to using the heat (to avoid the seasonal problems and costs of district heat pipes; officials say airily – industrial users).

FoE also found that the consultants’ air pollution and noise calculations were questionable.  Unrealistic values of background air pollution (low) and of background nighttime noise (high) were taken, and accepted by Council officers – officers who had received the message that these ‘renewable energy’ plants are a good thing, which would win the Council political brownie points.

In fact, these waste wood incinerators can be challenged on CHP, as the Waste Framework Directive (as revised 2008) is specifically worded.  Article 23(4) reads:

It shall be a condition of any permit covering incineration or co-incineration with energy recovery that the recovery of energy take place with a high level of energy efficiency.

Sedgwick omitted any numbers on efficiency, but a mass/energy flow chart released to the Inquiry showed 22% generation efficiency (likely to be an over-estimate).

They can also be challenged on ash.  Sedgwick just asserted their ash/char can be used for block-making, yet no-one would choose material with toxic metals, chlorides and high carbon content.  The EA says incinerator ash is to be presumed hazardous waste [5] until tested, so demand test evidence, including biotoxicity testing under the EA protocol.

Opponents may need some idea of alternative processes for contaminated waste wood.  The WRAP guidance [6] has high status.  Re-use comes before ‘energy recovery’ – chipped clean wood for chipboard manufacture or animal bedding, otherwise for rural paths and mulches, or for land reclamation.  For waste wood contaminated with PCP and CCA, carbon sequestration could be a better environmental option than burning, with the worst contaminated material (if a long term threat in landfill) treated by thermal desorption to recover the contaminants.   The Annex below (or jump to) outlines this and gives references on waste wood.

A second WRAP report [7] on options for treated wood waste gives little guidance, but interestingly does cite stronger efforts overseas over waste woods, particularly citing Switzerland as specifying  wood which is glued, painted, lacquered or surface coated with preservative is categorised as used timber. This must be disposed of in special waste wood incinerators, cement kilns or waste incineration plants. Waste wood which has been impregnated with preservatives under pressure, or that has been heavily coated with preservatives such as PCP, or has been coated with products made from halogenated organic compounds is identified as problematic wood waste.

If people want to run the arguments on dioxin production, potentially high in waste wood combustion, do make use of the FoE statement (available upon request) to the Barry Inquiry.  Note that pyrolysis and gasification may not produce as much dioxin as the waste wood boilers of the UNEP guidance we cited, but insist the onus is on the applicant to produce evidence.

Max Wallis, July 2010

Notes:

[1] The Renewables Obligation 2009: a new order  <www.wragge.com/analysis_4300.asp>.  Definitions of advanced and standard pyrolysis or gasfication are given at www.opsi.gov.uk/si/si2009/uksi_20090785_en_10 and UK WIN’s information on the new RO is at ukwin.org.uk/knowledge-bank/renewable-obligations-certificates/

[2]  One ROC is currently valued at £37, planned to inflate with prices, but floats around this level depending on the ROC market.  Banding is to be reviewed every 5 years, with option for an emergency review if a cheap technology emerges in a band and might knock out the others; the whole system is promised to last till 2027.

[3] ROCs are approved for heat energy from April 2010, but the system proposed would allocate them for heat output, with nothing to ensure the heat is used efficiently or even beneficially.  Heat pipes could be poorly insulated and the heat be piped to an uninsulated warehouse plus air-cooled heat dump for summer use.

[4] a) 20MW plant at Anchor Basin, Barrow-in-Furness, Cumbria
http://localportal.barrowbc.gov.uk/portal/servlets/AttachmentShowServlet?ImageName=43577
Says intended to use wood that is refined for reuse -  covering up that it’s waste wood from the neighbouring Bennett Bank landfill operator. No EIA; no condition on heat use.

b) 9MW biomass plant to generate electricity from reclaimed timber at Hudson Dock East, Barrack Street, Sunderland 08/04526/FUL
http://www.sunderland.gov.uk/committees/CmisWebPublic/Binary.ashx?Document=11602
The Officers’ report fails to mention EIA or ‘waste’ except saying that Process Guidance Note 1/12(04) using waste fuel is used for emissions and WID will apply.

c) renewable wood fueled energy plant (9MW) King George Dock, Kingston Upon Hull  00030735A   https://web5.hullcc.gov.uk/akshull/images/att9778.rtf
No EIA.  Objections made on grounds of contamination (railway sleepers; no use of waste heat.
Conditions set on waste arising within Hull and East Riding; on energy efficiency under Local Plan policy

[5] www.swardbishopscleeve.co.uk/Assets/Files/SWARD_stance_on_Residual_WasteFINAL.doc
see particularly the Annex from ENDS report, March 2009.

[6] WRAP Guidance for Mixed Wood Waste Producers on End Markets
http://www.wrap.org.uk/manufacturing/info_by_material/wood/uses_for_wood/guidance_for.html

[7] WRAP Options and Risk Assessment for Treated Wood Waste, TRADA Technology & Enviros Consulting Ltd  (2005)    www.wrap.org.uk/downloads /Options_and_Risk_Assessment_for_Treated_Wood_Waste.bb71f367.2237.pdf

Annex   Combustion of Wood?
Extract from Friends of the Earth Cymru Response to “Towards Zero Waste– One Wales: One Planet”, July 2009

WAG, like DEFRA and DECC, appears enthusiastic to increase the level of combustion of waste wood (both in this consultation and in the renewable energy route map for Wales [41]. Little or no consideration seems to have been given to the implications of the contamination of significant parts of this wood with industrial wood preservatives.
Since the 1970s sawn timber treated with water-borne preservatives has totally dominated the industrial preservation market (Krook et al., 2006b). Most of this wood has been treated with CCA-preservatives (containing copper, chromium and arsenic).

In 2002 wood containing hazardous substances was classified as hazardous waste according to the Swedish waste decree [73]. This legislation requires that such waste should be separately handled by operators who have permission to manage hazardous waste. Whilst the types of wood waste which should be classified as hazardous is, to some extent, open to varying interpretations the Swedish Environmental authorities have interpreted that wood treated by CCA and creosote preservatives is most likely to be regarded as hazardous waste [73]. This legislation has resulted in most Swedish combustion plants not having permission to handle industrial preservative-treated wood (Krook et al., 2006b).

Incineration of wastes containing CCA is likely to be problematic for several reasons:
•    Incineration and subsequent ash disposal greatly concentrates the chromium, often oxidizing it to the more toxic and mobile Cr(VI) form [74].
•    The copper is a potent catalyst for dioxin formation in incinerators [75-77]

Some older wood treated with Pentachlorophenol (PCP) such as railway sleepers can have extremely high levels of dioxin contamination. Asari [78] reported 21,000 ng/kg which exceeds the Stockholm Convention and EU levels at which the wastes are POPs wastes.

An increasing proportion of the wood now used in decking and outdoor applications (22% in 2006 and estimated to be 30% by 2011 [79] )is a wood plastic composite .  The plastics used are polyethylene (PE), polypropylene (PP) and polyvinyl chloride (PVC).  Any energy recovered from combustion of this composite would be largely fossil based  and would add, in the case of PVC based composites, significantly increased risks of dioxin and similar compounds if burned.

Rather than burn this contaminated wood the contamination it contains should ideally be treated.  Alternatively engineered landfill sites are a more appropriate disposal route than combustion.  In no circumstances should the wood be landfilled in unlined landfills [80] or open-burned. The Consumer Safety Information Sheet for Inorganic Arsenical Pressure-Treated Wood (14) cautions that CCA treated wood “should not be burned in open fires or in stoves, fireplaces, or residential boilers because toxic chemicals may be produced as part of the smoke and ashes”.  The Environment Agency does not appear to have taken this issue seriously to date and still permits the burning of contaminated wood on construction and demolition sites.  Open burning is banned in several US states [81] and should not be tolerated in Wales.
Notes:

41.    Welsh Assembly Government, Renewable Energy Route Map for Wales consultation on way forward to a leaner, greener and cleaner Wales. 2008.
73.    Krook, J., et al., Swedish recovered wood waste: Linking regulation and contamination. Waste Management, 2008. 28(3): p. 638-648.
74.    Jambeck, J., et al., CCA-Treated wood disposed in landfills and life-cycle trade-offs with waste-to-energy and MSW landfill disposal. Waste Management, 2007. 27(8): p. S21-S28.
75.    Stanmore, B.R., The formation of dioxins in combustion systems. Combustion and Flame, 2004. 136(3): p. 398-427.
76.    Shibamoto, T., A. Yasuhara, and T. Katami, Dioxin formation from waste incineration. Rev Environ Contam Toxicol, 2007. 190: p. 1-41.
77.    Hatanaka, T., A. Kitajima, and M. Takeuchi, Role of copper chloride in the formation of polychlorinated dibenzo-p-dioxins and dibenzofurans during incineration. Chemosphere, 2004. 57(1): p. 73-9.
78.    Asari, M., et al., [3] Environment International, 2004. 30(5): p. 639-649.
79.    Klyosov, A.A., Wood-Plastic Composites. 2007: Wiley-Interscience 698.
80.    Jambeck, J.R., T.G. Townsend, and H.M. Solo-Gabriele, Landfill Disposal of CCA-Treated Wood with Construction and Demolition (C&amp;D) Debris: Arsenic, Chromium, and Copper Concentrations in Leachate. Environ Sci Technol, 2008. 42(15): p. 5740-5745.
81.    Wasson, S.J., et al., Emissions of chromium, copper, arsenic, and PCDDs/Fs from open burning of CCA-treated wood. Environ Sci Technol, 2005. 39(22): p. 8865-76.

Waste Wood pyrolysis plant permitted at Barry, South Wales

Barry & Vale FoE deplore the decision of the Planning Inspector, quickly made after a curtailed 3-day inquiry where the voices of local people and businesses were hardly heard.

Allowing this major industrial plant pays little regard to neighbouring businesses and goes against aspirations for upgrading this part of the Dock for housing and light industry.

The permit as written by the Inspector goes against Welsh policies on the proximity principle for dealing with waste locally and on high energy efficiency, since he deleted the Council’s proposed conditions that were uselessly weak.  We believe this leaves it open to legal challenge.

The Barry & Vale group are lobbying for the Council to decide to challenge this shocking decision.

The evidence at the inquiry disclosed that similar plants have been permitted in Hull, Sunderland and Barrow-in-Furness, all without Environmental Impact Assessment, which FoE point out is mandatory for waste incineration plants over 100 tonnes per day (these burn 200 to 500 tonnes per day).

The company disclosed they are only interested in taking waste wood which allows them to earn ROCs (Renewable Obligation Certificates) as the business model relies on claiming this subsidy for being “advanced technology” even though they would be only 20% efficient.

Back in May 2010, DISC worked in conjunction with North Yorkshire County Councillor John Savage to send a latter to George Osborne (see full letter reproduced below). This attracted regional media coverage – see, for example, the article in the Yorkshire Post entitled Cameron lobbied to halt finance for national drive to burn waste.

More recently DISC submitted a substantial examination of their support for zero waste and their opposition to the incineration of waste on economic, environmental and health grounds, in response to the Review announced by Caroline Spelman in her “Waste – new thinking for a new economy” speech to Futuresource on 15th June 2010.

Download DISC’s 32-page consultation submission [PDF].

Now DISC has set up an online petition at: http://www.gopetition.co.uk/petitions/dont-incinerate-north-yorkshire.html

The petition calls on the councillors of North Yorkshire County Council and the City of York Council:

1. To listen to the community;
2. To vote against the proposed waste management plant at Allerton Park;
3. To urgently review their waste management strategy;
4. Specifically to review in full a wider set of more innovative and sustainable solutions for the future that match current national policy, reflect up to date technology and the state of the economy by going beyond large-scale incineration, reflecting the views of the public of North Yorkshire today through full, open and responsive dialogue with the public, and safeguard the heritage of those who live and work in the county now and in the future.

Sign the petition now!

Further information about the proposed Allerton Quarry incinerator can be seen at the Crown Hotel, Borobridge from 11am-7pm on July 15th Crown Hotel, in Harrogate on Saturday 17th July from 10am-4pm and on Monday 19th July at Knaresborough House, from 10am-6pm.

Letter to George Osborne, Chancellor of the Exchequer

18th May 2010
Immediate potential savings of £2bn – £3bn.
Financially disastrous waste PFIs being awarded nationally
North Yorkshire imminent – please halt it now.

Congratulations upon your recent appointment as Chancellor of the Exchequer.

I am writing in my capacity as Chairman of North Yorkshire County Council to highlight the urgent need to save money immediately and to implement the Conservative waste strategy of anaerobic digestion and high recycling levels. This is a manifesto and coalition agreement detailed in item 11. Environment of the ConLib agreement.

This issue is particularly urgent as genuine and immediate cost savings are possible and the figures nationally in this respect are significant – between £2 and £3bn has been budgeted in PFI credits to support incineration projects up and down the country. The PFIs are not fixed cost contracts, will considerably, bind local governments if entered into precipitately and are driving forward change that is far from best practice. In terms of financial risk they may actually be the tip of the iceberg as is evidenced by the recent massive overspend on the Manchester waste PFI which jumped from £100m budget to £124.5m during implementation.

The incineration industry also receives an irregular subsidy in the form of a 90% tax discount on disposal of the ash, some of which is toxic but NOT fully regulated as such.

This was enshrined in Statutory Instrument 1996 No 1528 which in essence has served its time as a policy and generated sufficient investment in the industry to define whether incineration technology has the legs to deliver a sustainable contribution to the energy strategy for the UK. Overwhelming evidence suggests it has not and it should be withdrawn.

Our own county council has wrestled with central directives to manage landfill diversion but in the absence of clear guidelines over CO2 emissions, food waste and waste collection methods, large quantities of money and valuable time has been spent to no avail. My county of North Yorkshire now faces the real prospect of implementing a large scale recycling programme only to then scale it back in 2013-2014 as an incinerator comes on line.

There is a large body of evidence to show that incineration is a poor strategy:

• Investment levels are far higher than recycling, composting and anaerobic digestion options (Peter Jones Waste Consultant – London Mayoral Independent Appointee)
• Energy recover levels in comparison levels are very poor (ICF recycling) not least because transmission losses and energy storage is a massive inherent technical problem
• Anaerobic Digestion holds the advantage that energy is stored in the form of fuel and can be localised to minimise transmission losses.
• Costs are very high and the contracts last over 25 years – leaving any local authority exposed to large market shifts in costs and fuel mix. They will be unable to take advantage of new technology when it comes onstream.
• CO2 levels will rise in comparison to landfill (Peter Jones OBE)
• Incineration creates very few jobs and the net effect is to take revenue out of the local economy. Most of the engineering is foreign and the operators are multinationals.
• Materials banned from disposal into landfill are not similarly segregated from incineration but as their value rises through scarcity and the effect of the Landfill Tax ratchet, these high calorie sources are likely to become more scarce.
• Central electricity generators are installing significant capacity to co-fuel burn e.g. Ferrybridge, North Yorkshire which will radically alter gate prices downwards by about 50% and add 1 million tonnes demand to the market for waste derived fuel drawn from an 8o mile radius from Newcastle to Nottingham, Hull to Manchester.

Boris Johnson has recently appointed Peter Jones as London’s external consultant and we have brought Peter and Dr Paul Connett (Cambridge and St. Lawrence University in Canton, NY where he specialized in Environmental Chemistry and Toxicology over to explain the economic situation to the County Councillors. Over 140 council officials from a cross section of the executive to parish council chairmen attended the conference.

Well organised programmes in leading authorities have achieved very high landfill diversion rates e.g. West Midlands is now at its 2020 landfill target already!

Our council, among many others, have not responded positively to the Landfill Tax and now see incinerators as a quick fix to meet their targets late. However as Peter Jones shows in the attached slide the incineration route is inherently flawed – with CO2 levels at their lowest in anaerobic digestion and recycling and rising again to new heights with incineration.

The incineration route is fundamentally underpinned by two financial packages.

Firstly PFI credits in our own area for incineration plans are allocated at £65m – across the country there are dozens of other councils planning the same route based on the grants and the tax subsidy for ash disposal. It is calculated that between £2 and £3.2 billion nationally is involved just for the incineration plants.

In addition to this grant, the operators will receive a massive £41.50 discount on Landfill Tax (reduce to £2.50 per tonne) on disposal of potentially toxic incinerator bottom ash (IBA) – the material that drops out of the furnace.

The outgoing Labour administration reneged on a full review of this discount only last month. Withdrawal of the subsidy was stopped by laggard authorities arguing that they had committed upwards of £1m each on coming to the decision to use the incineration route and were well advanced in their planning. Were the subsidy to be withdrawn this would probably generate another £60m in tax revenue in this area and at least make it clear to ratepayers nationally who effectively pay the full rate that this Conservative government is keen to avoid subsidising polluters.

Generally withdrawal of PFI credits for incinerators will prove a good political move – the programme would generate jobs locally in all authority areas in wage groups which are likely to spend locally and keep the wealth circulating. There are up to 20 times more jobs in recycling versus incineration and in our own area up to 1000 new jobs could be created. Local brown field sites will be required for processing. Reusing materials also reduces a reliance on exports which will benefit the pound. And the routes to recycling and anaerobic digestion are far more solid and less likely to generate a project overspend. This will move us far closer to CO2 targets quicker and more sustainably.

Thank you for your consideration.

Yours
County Councillor John Savage – Ainsty Ward

Hansard records the following exchange, which took place yesterday (30th June 2010) at the House of Commons.

Nadine Dorries (Conservative MP for Mid Bedfordshire):

The American waste giant, Covanta, is proposing to build in my constituency an incinerator about the size of Wembley. Will the Prime Minister give an assurance that decisions about such matters will be made at a local level in future?

The Prime Minister:

My hon. Friend is right to raise this, and it is right that decisions should be made locally. We want to make sure that all the latest technology for alternatives to incineration is considered, so that we can make sure that we are using the best ways to achieve a green approach.*

This reply from David Cameron is welcomed by UKWIN and will be seen as a positive sign by the coalition of independent Environmental groups campaigning against waste incineration in Gloucestershire and the global Anti-Covanta movement.

Further details of the current situation in Gloucestershire can be found on the Gloucestershire Against Incinerators website, created to serve the Gloucestershire anti-incineration waste campaign.

Several independent Environmental groups are actively campaigning against waste incineration in Gloucestershire, including: GlosAIN (Gloucestershire Against Incinerators), GlosVAIN (Gloucestershire Vale Against Incineration), GFOEN (Gloucestershire Friends of the Earth Network), and the Bishops Cleeve-based SWARD (Safety in Waste and Rubbish Disposal).

The website features a petition calling for Gloucestershire County Council, the District Councils of Gloucestershire and the Government not to accept a large scale incinerator as the solution for dealing with residual waste in Gloucestershire because:
• Tackling climate change is a priority and better technologies are available
• It produces toxic fly ash
• It reduces the incentive to reduce, reuse, recycle and compost thus wasting resources
• It could be a high risk, long term, contractual expense for the local taxpayer
• If needed, residual waste should be treated under short term contracts by small local facilities

The false claims made about incineration by some in the waste industry have been recently criticised by GAIA, see EU incinerator subsidies worsen climate change. GAIA stands for The Global Anti-Incinerator Alliance: Mobilizing grassroots action against the spread of incinerators and other polluting, end-of-pipe waste technologies. GAIA also stands for The Global Alliance for Incinerator Alternatives: Building the movement for environmental justice, local green economies, and creative zero waste solutions.

*Note: According to a video recording David Cameron actually said “Well, my honourable friend is right to raise this and it’s right that decisions should be made locally, and we want to make sure that all the latest technology in terms of alternatives to incineration are looked at so we can actually make sure we are using the best ways to make sure that we have a green approach”.

A big part of the energy produced by European incinerators is considered to be renewable energy, which allows them to receive considerable rate premiums and subsidies. This has the effect of a false green subsidy to burn waste that could be recycled or composted. In reality these subsidies end up creating the opposite of the intended effect: more greenhouse gas (GHG) emissions in the short term, less sustainability and less incentive to green the economy.

Firstly, the report denounces the biased accounting of CO2 emitted by incinerators. Because of a mistaken understanding of the IPCC guidance up to 50% of the emissions from burning waste are not accounted for, albeit the growing consensus about the dangers of considering burning waste of biogenic origin as carbon neutral – see Bioenergy: a carbon accounting time-bomb for details of this “biogenic fudge”.

Secondly, the current directive on Renewable Energy (2009/28/EC) opens the door for subsidies and premiums to reward the generation of energy from burning the biogenic fraction of waste. This works as a market disincentive for prevention, reuse and recycling and contradicts the Waste Hierarchy spelled out in the Waste Framework Directive (2006/12/EC).

According to GAIA Europe’s hard working Coordinator, Joan Marc Simon:

The current system of premiums to incineration is flawed because it penalizes saving energy. Due to the fact that recycling and composting do not generate electricity they are not eligible for renewable energy premiums whilst burning waste, which generates electricity inefficiently and is a step lower in the waste hierarchy, still manages to get such reward. The market incentives given by the Renewable Energy directive distort the waste hierarchy; burning waste is given priority before composting which is a step higher in the hierarchy.

The report studies the situation of the premiums for energy from incineration in 4 EU countries: Flanders in Belgium, France, Italy and Spain.

On the top of the billions in grants and funding provided by the EU cohesion funds and the European Investment Bank to build new incinerators, if all the EU countries rewarded energy from incineration as the Spanish or the Belgians do the EU and member states would be spending €2.5 billion per year to promote burning resources.

If the EU countries followed the Italian scheme up to €36 billion of taxpayers money would go to subsidise energy from incineration. With this money the EU could afford to finance the EU smart grid in only 7 years!

The report calls for an accurate and valid accounting of the emissions from incinerators. Currently around half of its emissions are not accounted for.

If the subsidies and premiums given to incineration are to be continued at all, the EU should develop an EU-wide policy and a methodology to calculate the energy savings associated with prevention, reuse and recycling and make them also eligible for premiums or fiscal compensation.

The EU should prioritise the energy from anaerobic digestion before incineration because of its more favourable externalities in soil productivity and carbon sequestration.

The EU has good directives for different waste-streams but it will be difficult that prevention and recycling take off in Europe as long as the money and policy go to favour incineration instead of rewarding the energy savings, lower emissions and higher sustainability provided by prevention, reuse and recycling

concludes Simon.

Click here to download the report

GAIA is a worldwide alliance of more than 600 grassroots groups, non-governmental organizations, and individuals in over 89 countries whose ultimate vision is a just, toxic-free world without incineration.

Visit GAIA’s website.

As described by Sloley:

The document is written in an easy-to-read style for use by Audit Commission staff and was not meant to be seen outside of the Commission…It was issued in August 2007 to Audit Commission inspectors working with local authorities to give an overview of waste management and recycling practices, describes waste management as “not rocket science”.

…incineration is identified as a “contentious area” in the Audit Commission guidance. Although it is accepted as “better” than landfill, the document states that “burning mixed was is no longer really sensible practice”.

And, raising questions over the use of incineration alongside other disposal methods, the Audit Commission claims a detrimental link between council recycling performances and the use of incineration as a disposal route. It states: “For a long time, councils with incinerators have had poor recycling rates”.

According to the Audit Commission website:

The Audit Commission is an independent watchdog, driving economy, efficiency and effectiveness in local public services to deliver better outcomes for everyone. Our work across local government, health, housing, community safety and fire and rescue services means that we have a unique perspective. We promote value for money for taxpayers, auditing the £200 billion spent by 11,000 local public bodies.

Our powers and responsibilities, and those of the auditors we appoint, are set out in Acts of Parliament, including the Audit Commission Act 1998 and the Local Government Act 1999. These laws give us responsibilities in relation to auditing, assessment, studies and comparing information, and also give us the power to get the information we need to support this. We use this information in different ways, to help public organisations use their money well and to improve services.

[The guide] states that incinerators “need a regular supply of waste” and claims: “The importance is not to embark on [an] arrangement that will prevent another [treatment method] taking place. Incineration has typically been a culprit in this – the contractor requires, say, 100,000 tonnes of waste a year to operate the incinerator. This is the big difference between incinerators and other treatments.”