Veolia Environmental Services is once again facing difficulty finding enough waste to feed their incinerator at Bernard Road, Sheffield. When planning permission was granted for the 225,000 tonne replacement incinerator for Sheffield in 2002 (ref. 01/1035/FUL) Veolia claimed that they would have no trouble topping up with local C&I waste.
This is a fascinating case study regarding how predictions and assumptions can be wrong, with reductions in residual waste arisings underestimated and the availability of alternative sources of waste overestimated, and how claims about the purported need for a proposed facility confidently made by applicants at the time of an initial planning application are of little value.
Beyond the fact that residual MSW was far below that estimated, with further reductions anticipated as a result of introducing Alternative Weekly Collections across Sheffield, one of the most interesting aspects of this case is how hard Veolia claim to find it to actually get hold of C&I in the real world, with around 5-10% of C&I arisings deemed as suitable available feedstock. Of course, whilst ~10% (or less) of estimated C&I arisings may be available for incineration it is possible that much of it is recyclable as: “the recorded data suggests that up to 97.5% of the C&I waste landfilled in the [North West] region could be recycled if the correct facilities and services were available” (Source).
According to their recent planning application (ref. 12/03137/FUL): “As part of the 2010 Planning Variation a report was commissioned by VES to attempt to establish an accurate volume of C&I waste which could be used to inform the likely future inputs to the ERF. This report concluded that in 2006/7 (the latest available data at the time) Sheffield businesses produced an estimated 654,000 tonnes, of which it is estimated that following recycling/composting only 130,500 tonnes of C&I waste would be suitable feedstock material at the ERF…This theoretical figure is, however, considered to be an absolute maximum…The theoretical figure however fails to recognise the significant competition for a limited volume of waste from other competitors within Sheffield – competitors both big and small who are competing for the same tonnage. This also involves competitors coming into the Sheffield area from neighbouring districts such as Doncaster, Rotherham, Bassetlaw and Chesterfield. As a consequence only around 60-70,000 tonnes per year of the potentially suitable C&I waste feedstock is assessed as being available to the ERF.
Veolia’s submission goes on to state that: “…As set out previously, VES previously commissioned a study conducted by RPS, submitted as part of the previous application to vary condition 3, which estimated that only 45,000 tpa of Sheffield’s suitable C&I waste is actually available to the ERF… Of the C&I waste that is landfilled, it is acknowledged that a proportion of it would not be suitable for use at the ERF…In view of the success of MSW recycling and waste minimisation initiatives within Sheffield, the facility has had to increasingly rely upon top-up C&I waste (trade waste) feedstock. However, owing to a combination of a drive to minimise wastes and recycle greater volumes, allied with the economic slowdown, along with the unrestricted and highly competitive nature of the C&I waste market in Sheffield, the amount of suitable C&I waste available to the ERF has fallen to approximately 45,000 tpa. It is anticipated that the C&I waste arisings may fall further as landfill diversion initiatives are rolled out across the City”.
In December 2010 Veolia was granted temporary permission (ref. 10/03861/FUL) to “receive up to 50,000 tonnes of waste from outside of the Sheffield Waste Disposal Area, namely Rotherham, NE Derbyshire, Barnsley and Chesterfield” for six years from the 23rd of May 2011. Veolia argued that there just wasn’t enough suitable local C&I and MSW, and that their gate fee was insufficiently competitive to convince local businesses to use their incinerator.
Now Veolia has come back to the local authority to ask for 15,000 tonnes more waste to be taken from outside of the Sheffield Waste Disposal Area, that this 65,000 tonne a year should be allowed from further afield to include: “Doncaster, Bolsover, Bassetlaw, Newark and Sherwood, Amber Valley, Derbyshire Dales, High Peak, Ashfield and Mansfield”, and that the variation be made permanent.
It appears that this may be part of a strategy to abandon plans for a new incinerator in Nottinghamshire following Veolia’s decision to withdraw their legal challenge to the refusal of planning consent for the Sherwood Forest Incinerator. It now seems likely that any additional residual waste disposal capacity would be provided by the existing incinerator at Eastcroft for those collecting authorities nearer to Nottingham with the rest going to the Sheffield incinerator.
Whilst the Revise Project Plan has not been announced (or indeed approved by the Cabinet), the following passages from Paragaph 5.12 of the planning application does seem telling: “In seeking planning permission to vary the planning condition as proposed VES wish to primarily draw upon increased quantities of MSW and C&I arisings from the North Derbyshire (including Chesterfield, Bolsover, Amber Valley and Derbyshire Dales) and Nottinghamshire (including Ashfield, Mansfield, Newark and Sherwood and Bassetlaw) areas which are well connected to Sheffield. The municipal waste from Nottinghamshire is accessible through VES’s existing contract with Nottinghamshire County Council and can provide the facility with much needed certainty of supply”.
Furthermore, Paragraph 7.2 of the recent application states that: “It is proposed that increasing quantities of waste are derived from the North Nottinghamshire area (primarily bulking facilities in the areas of Worksop, Sutton in Ashfield and Newark) which is contracted to Veolia over the long-term”, and on page 41 it is stated that: “The Nottinghamshire municipal waste provides the only local source of reliable, secured waste which can be used to top up any shortfall at the ERF over the remaining term of the Contract. From 2016 the predicted ERF shortfall will be some 63,241 tonnes which can be addressed through the import of waste primarily from Bassetlaw District with additional tonnage derived from the Ashfield and Mansfield (also bulked at a local transfer station close to the M1) and Newark and Sherwood Districts.”
According to the recent (November 2012) variation application:
1.7 Since the granting of planning permission and the development and operation of the plant in 2006, circumstances relating to the generation of municipal waste, successful recycling initiatives and overall a progression in waste management practices within the City of Sheffield have led to a shift in the way waste arisings within the local area can be most sustainably managed. The successful approach to waste management in the City and removal of municipal imports from areas where new contracts will now see a diversion away from the facility has resulted in the facility having to rely upon an increasing proportion of trade waste otherwise known as Commercial and Industrial (C&I) wastes derived from the same catchment area. The 2010 variation application recognised this shift in waste management and attempted to address the situation.
1.8 It is likely that this situation will become even more pronounced following the implementation of Alternative Weekly Collections (AWC) planned across the City. It is now considered unlikely that sufficient Municipal Solid Waste (MSW) and C&I waste will be available to the ERF under the terms of the current planning permission, as restricted by the revised condition 3 and as such the efficiency of the Plant and its associated District Energy system will not perform to its optimal level. This proposal seeks to definitively address this situation and to invoke the provisions of the condition that allow flexibility in the area from which waste is sourced where agreed with the Local Planning Authority. This will secure the future inputs to the Plant and avoid further applications to the LPA…
5.6 The expectation at the time planning permission was granted in 2002 was that the facility capacity would be accommodated by 195,000 tonnes of household waste arisings with the remaining 30,000 tonnes of input made up of C&I waste (trade wastes). At the time it was also predicted that household and other municipal wastes arisings would continue to grow by 2% annually to 2006 with no growth thereafter (in accordance with expectations at the time). At that time recycling and composting of Sheffield’s municipal solid waste (MSW) was undertaken at a rate of only 4% and it was assumed that this would rise to 18% by March 2008.
5.7 Over recent years, particularly since the publication of the Waste Strategy England 2007 there has been ongoing change in the management of waste materials, particularly MSW which has been targeted. Such changes are welcomed and are part and parcel of the creation of sustainable waste management practices throughout the UK. In the case of Sheffield a recycling and composting rate of almost 30% was achieved over the period October 2010 to September 2011 (based upon Defra data). The Council continues to strive for Sheffield residents to further reduce household waste disposal by championing a ‘Lids Down’ approach to waste generation. Total MSW generation in Sheffield in the calendar year 2011 stood at some 209,010 tonnes per annum. Building on this drive to reduce waste arisings further it was announced that there would be a phased roll-out of Alternative Weekly Collections (AWC) across Sheffield. Experience elsewhere has shown that this will lead to a noticeable further reduction in waste tonnages collected from the kerbside and this is corroborated by predicted tonnage data calculated by the Waste Collection Authority. During 2011 a tonnage of 121,432 tonnes (representing approximately 58% of the total tonnage) was delivered to the ERF for treatment.
5.8 The consequence of Sheffield’s success in increasing the rate at which MSW is recycled along with the reduction in waste growth has meant that there is currently a shortfall in available municipal waste feedstock for the ERF available from the City. The operating shortfall has therefore had to be increasingly made up with municipal waste from neighbouring authorities and from C&I waste arisings.
The amount of municipal waste available from neighbouring authorities is expected to decrease as their waste disposal contracts evolve and new disposal facilities are provided. The magnitude of the future shortfall, especially after the development of these alternative facilities, is such that the replacement fo [sic] this deficit can no longer be sustained by importing C&I tonnage given the competitive nature of this market and restrictions placed upon the operation of the ERF through the planning permission. Consequently it is predicted that there will be insufficient waste available in the future to meet the ERF’s operational requirements. Any shortfall in feedstock potentially results in a reduction in the efficiency of the plant and its energy outputs as well as potential increases in shutdown time and the associated use of fossil fuels to maintain combustion temperature control and support the District Energy Network during such periods.
[Appendix on Need:] Municipal Solid Waste Arisings in Sheffield
As described previously, in recent years the amount of MSW arising in Sheffield has fallen year on year. Since the planning application for the development of the new ERF was submitted to Sheffield City Council in 2001 the amount of MSW arising in Sheffield has fallen by nearly 80,000 tonnes (58,510) from 285,000 tonnes per annum (tpa) 2000/01 to 209,010 tpa in 2011. Indeed, since the MSW arisings forecasts were carried out for the Yorkshire and Humber Plan, the arisings for Sheffield have actually fallen from 249,000 tpa of 2005/06 to 226,490 tpa in 2009/10 rather than increasing to 252,600 tpa; a difference of 24,510 tonnes. This decline has continued and is expected to continue following the introduction of AWC. At the same time, the recycling/composting rate assumed in 2001 at between 18% to 27.5 % was lower than the current targets.
Accordingly, the decline in MSW arisings at the facility may continue into the future particular if the City Council aims to achieve the targets set out within the Waste Strategy England (2007). This is a matter of some debate as the Government Review of Waste Strategy confirms that it is not the intention to use the UK Waste Framework Directive target to set a 50% recycling benchmark for every local authority – this is a particularly challenging target across many of the Cities in the UK. Consequently figures used to inform the projected shortfalls at the facility have assumed that waste inputs will remain at the levels predicted following the introduction of AWC – 116,827 tonnes in 2013 falling further to 108,857 tonnes by 2020. Currently total household waste recycling, composting and reuse in Sheffield (for the period April 2010 to March 2011) is around 30% which is below the level identified in the Waste Strategy England (2007), but within the Waste Strategy there is a stated aim to increase recycling levels further…
…Against this backdrop of falling C&I arisings, those generating the waste will always seek to manage it wherever practical at a competitive rate. Whilst the ERF is competitive with a number of other waste management solutions it cannot generally compete with low technology solutions such as physical treatments and landfill disposal, given the significantly higher costs of the ERF technology and its maintenance compared with that of landfill even taking into account Landfill Tax and waste transfer costs where relevant…
…In addition, there is no means of restricting the distance C&I waste may travel for management and eventual disposal. The C&I waste market is reliant upon price with contracts awarded on a short-term basis. Consequently this can lead to the export of substantial volumes of waste beyond the Sheffield administrative boundary…The ERF has to compete for C&I waste with at least 32 other operators accepting similar waste within Sheffield alone.
…In accordance with the waste hierarchy, it is of course more appropriate to recycle waste than recover energy at the ERF, and as such, this waste is not available to the ERF. Reduced volumes of suitable pre-treated residual C&I waste is then available as a fuel stock for the ERF…