European Commission plans on Waste to Energy

We have shamelessly copied the following message from a Quaker round-robin.

It’s an opportunity to help influence the EU’s future strategy on waste treatment, in particular to object to proposals which contradict the EU’s own climate commitments by promoting a polluting and inefficient form of energy.

Responses to the proposals are required by the end of March 2016.


The European Commission has published its plans on waste-to-energy: burning waste to create small amounts of energy and wasting valuable materials.

Despite circular economy principles emphasising the need to use our resources in a more efficient way, incineration, the second-worst form of waste treatment (only better than landfilling) is still being promoted by the EU. If you are concerned about this issue, take action to by giving your reaction here:

http://ec.europa.eu/smart-regulation/roadmaps/index_en.htm#fbform

[Search for “Waste to Energy” in the Name box, and the document “Waste to Energy Communication” will appear. Click on “Open” on the far right under the heading “Give your feedback”]

Below are a few suggested points for you to use in your reaction. Please try not copy and paste these exactly, as the Commission may disregard identical (or very similar) responses. The deadline for giving your feedback is the end of March.

The EU’s roadmap:

  • classifies incineration with energy recovery as renewable energy,
  • suggests that waste-to-energy is the best treatment for non-recyclable waste, and,
  • contradicts the EU’s climate commitments by promoting a polluting and inefficient form of energy.

Take action today by responding to the roadmap.

Feel free to contact me if you have any questions.

Let’s work together to build a more sustainable Europe!

George Thurley
Project Officer (Sustainability)
Quaker Council for European Affairs (QCEA)
Quaker House, Square Ambiorix 50, 1000 Brussels
Twitter: @QCEA Web: QCEA.org | qceablog.wordpress.com
Telephone: +32 2 234 30 62


Energy from Waste response bullet points

Please do not copy and paste these exactly, as the Commission may disregard identical (or very similar) responses.

  • The contribution of waste-to-energy to Europe’s energy creation is limited – if we burnt all the municipal waste we are not required to recycle it would only provide 2% of our energy demand by 2020.
  • Europe should be trying to reduce our waste generation, not relying on it to provide energy. Burning waste produces more Carbon dioxide per megwatt-hour of energy than any fossil fuel.
  • “Non-recyclable waste” and materials should be eliminated at design stage, not burnt – promoting waste-to-energy addresses one symptom of our poor waste management systems, rather than addressing the root cause.
  • Building incineration plants encourages waste creation to feed these plants, and requires huge investment.
  • The targets set in the new circular economy package would mean that by 2030 only 25-35% of Europe’s waste should be incinerated – it is not worth investing in incineration plants for this amount.
  • Many member states already have too many incinerators with not enough waste to burn. The EU should require Member states not to allow new incineration plants.
  • The waste hierarchy is not a ladder: it is possible for countries dependent on landfill to skip incineration altogether by focussing on recycling and reuse.
  • In a true circular economy, any burning of waste is a failure.
  • The European Commission should impose a moratorium on the construction of new Waste-to-energy plants until it has performed an analysis on the current capacity of incineration plants.
  • The Commission must then develop plans on how to reduce existing over-capacities of incineration, rather than encourage their use for long-term facilities like district heating.
  • This roadmap ignores the role of civil society, and local governments, by not mentioning them in the list of stakeholders, despite the considerable health and environmental concerns.
  • Burning waste is not renewable energy (although we can continue making waste, we should not – waste is not comparable to the sun or wind!)
  • In fact, burning waste is one of the most polluting and inefficient forms of energy in existence.
  • Waste avoidance and recycling can save more energy – the energy embedded in products and materials – than burning waste could produce, and without any extra greenhouse gases being emitted.

There’s something in the wind…

Amidst all the excitement of “Particulart: Up in the Air”, let’s not forget our origins, critiquing the Incinerator. In the 16th July edition of Express & Echo, there was a short update on Recycling in Exeter.

2015-07-16 E&E p44

Diana and I couldn’t let this pass. I was particularly struck by the nonsensical “contributing 3MWh per hour of operation to the National Grid”… which just means the Incinerator’s generation capacity is 3MWe, and tells us nothing about the number of hours of operation and how much electricity it has actually generated. Diana is currently trying to get hold of some data for generation and operating costs. In the meantime, I have compared it with the capacity and cost of wind generation.

OK, so according to its communications, the Incinerator was expected to cost £45m, and has a capacity of 3MWe. That’s £15m per MWe. The cost of generating each kWh is to be determined.

Let’s take offshore wind, which the UK is quite good at. Each turbine in the London Array, commissioned in 2012, has a capacity of 3.6MWe. At the moment, the average cost of capacity is 2.5-3.0 million Euro/MW, or up to £2m per MWe; and the average cost of generation is 161 euros ($208) per MegaWattHour, or 11p/kWh.

So the Incinerator has a smaller capacity than one wind turbine, and costed 7.5 times as much per MW!!

Here’s the Incinerator equation for garbage in, garbage out:

(carbon content of waste + rest of waste) + oxygen + other reactive gases
   → carbon dioxide + other flue gases + flyash

Some estimate the carbon content to be 27% of the total waste, which means that incineration of 1 tonne of waste would produce approximately 1 tonne of carbon dioxide. Others put the carbon content at nearly 50%, which means 1 tonne of waste in, nearly 2 tonnes of carbon dioxide out.

The Incinerator is designed to accept up to 60,000 tonnes per year of waste. That means 60,000 to 120,000 tonnes of carbon dioxide emissions every year. Exeter has a population of about 120,000. Ignoring the carbon footprint of building the Incinerator and offshore wind, and of other operations such as waste delivery, flyash removal and maintenance…

The Incinerator adds 0.5 to 1 tonnes of carbon dioxide to every person’s annual carbon budget. Offshore wind is zero carbon.

Furthermore, that is 60,000 tonnes of waste that has not been reduced, reused or recycled. It is not very surprising that recycling rates in Exeter have gone down, since the Incinerator needs feeding.

Now let’s turn to Diana’s main concern…

Food waste makes up about 36% of the waste input to the Incinerator, and it could instead be be composted or processed more efficiently in a anaerobic digester to produce biogas. The point about the garden waste scheme is not relevant regarding food waste, as the scheme really does only collect garden waste.

Diana thinks the point about the cost of food waste collection is a cover up for the fact that Exeter City Council’s negotiations with Teignbridge and East Devon District Councils on food waste collection have recently collapsed.

Here’s another article from Monday’s Express & Echo, which makes the arguments over the cost of collection academic.

2015-07-20 E&E p7

So if food waste is rightly diverted away from the Incinerator, where will all the waste to feed it be sourced?

 

Further communications with Devon CC

Diana followed up Devon County Council’s response to our initial letter about Particulart on 21 December 2014 by email:

Just a note to thank you for taking the time to give a thorough response to our letter.

I remain concerned that the long term health impacts aren’t being assessed and I will feed that into the low emissions strategy plan feedback for ECC.

The Government document on the guidance in relation to reducing contractor costs did seem to me to include PPP contracts and I hope the Council can follow that up. How much is the value of the contract with Viridor?

I do hope that DCC will look to introduce a zero waste strategy over the coming years, rather than continuing with these incineration plans.

Perhaps just before Christmas wasn’t the best time to write, and a bit of prodding was required. It elicited the following response on 13 February 2015:

The value of the Exeter Efw contract is around £210 million over the contract term. As you can imagine the investment to build these plants is significant – approx £46 million for the Exeter facility. Hence the contracts for their operation have to be for a longer term duration in order to cover the capital and operational costs.

The County Council working in partnership with its Districts are committed through our Waste & Resource Management Strategy (http://www.devon.gov.uk/dcc_waste_strategy_review.pdf) to manage waste at the top of the waste hierarchy promoting waste reduction, re-use and recycling before recovery and we have high targets to aim for. Devon is still among the top performers nationally for recycling and the opening of the Exeter and Plymouth plants will not affect that. The Efw plants are being used to divert waste away from landfill and recover value from it, not to impact on waste reduction, re-use and recycling.

Councillor responses

Councillor Keith Owen responded to our letter of 6 October after only a few days. He is the Portfolio Holder for Environment, Health and Wellbeing on Exeter City Council. Unfortunately, he was unable to attend the exhibition launch.

Cllr Owen response - RE_ Energy from Waste

Councillor Roger Croad, who is the Cabinet Member for Community and Environmental Services on Devon County Council, required substantially more prodding. Eventually, in late November, we received a very full response (pdf) from the County Waste Manager.