Royal Commission on Environmental Pollution

As I recall, we have not spoken since I left the Environmental Services Association last March to take over from Ray Palin as Director of the Energy from Waste Association (EWA).

You will be aware that EWA is the recognised UK trade body representing the key developers and operators of energy from waste plants, together with leading players in the field from the legal profession, technology suppliers and environmental consultancies. The Association's membership includes major companies active in creating and implementing sustainable waste management solutions covering all recovery options.

Having discussed the Commission's study in detail with colleagues on our Planning Group, we have collectively come to the view that the substantive planning issues we would wish to raise have been covered in detail in both our recent response to DETR on A way with waste, together with our submission to the Environment Agency consultation on Extended Public Consultation on Selected Licence Applications. I have, therefore, enclosed a copy of both these documents for the Commission's full consideration.

We commend the Commission for conducting this important study into environmental planning at such a crucial time, as it comes in the midst of Government's deliberations leading to the publication of the forthcoming National Waste Strategy (expected December 1999/January 2000) I cannot underestimate the importance that a coherent and cost effective planning system would have on the viability of the EfW sector and the achievement of Government' s policies in this regard. I would ask, therefore, that consideration is given to those aspects of particular relevance in our enclosed responses. Any positive recommendations in relation to the management of the current planning restrictions and impediments would be warmly received by the Association.

I would be grateful if you could update the Commission's mailing list in order that all future correspondence, on this and other studies, is sent to myself in the first instance.

If there are any particular issues on which you would like any more detail or explanation, I can confirm that the Association would be delighted to be able to assist further.

14th October 1999

Dear Mr Winter

Thank you for your letter dated 16th July. EWA welcomes the opportunity to comment on this important consultation document.

Please find enclosed our submission for your consideration. In welcoming the proposals for extended public consultation on selected licence applications, EWA urges the Agency to enter into early dialogue with the Association in the development of the necessary delivery mechanisms.

Yours sincerely

Dr Stuart McLanaghan
Director
encl:

Strategic Comments

1. The Energy from Waste Association (EWA) fully supports the proposals, in particular the intent to "improve the understanding of, and enhance confidence in, Agency decisions, resulting in their wide acceptability". Any mechanism(s) that has potential to ensure these considerations are met should be commended.

2. Given the current relatively low public appreciation of the necessary infrastructural requirements to deliver sustainable waste management solutions, it is perhaps inevitable that many planned waste management facilities, including energy from waste (EfW), give rise to public concern.

3. For the Agency's proposals to be effective, it is imperative in the first instance that a widespread public education and information programme is conducted to remove negative public perceptions surrounding waste management and, in parallel, raise awareness of the environmental and economic case (Best Value) of all recovery options, including EfW. We believe that it is not enough in isolation to disseminate information about waste management practices. Instead, a wider societal appreciation is required (i.e. that it is our choices as consumers that will ultimately shape the necessary direction and size of the UK waste management industry in the future.)V
4. EWA is acutely aware of the difficulties in getting these complex messages across in readily digestible sound bites, however, these issues have been put on the "too hard" list by Government for too long. The Agencies' would clearly need to work in parallel with other current national initiatives e.g. Are You Doing Your Bit. A more informed general public would then be able to participate more fully in an extended consultation process.

5. The Agency's proposals come at a crucial time for the waste management industry as it gears up to meet the profound challenges associated with delivering sustainable waste management. It is vitally important, therefore, that the extended consultation on selected applications can deliver within to be agreed timescales. In this respect, paragraph 1.5 is key, stating. "Greater public consultation in the decision-making process should ensure that no significant issues of public concern - that are relevant to the decision - are overlooked and that the weight given to the various issues is well founded". Thus, the Agency must ensure that the proposals are not abused and used as a blocking, or delaying mechanism by 'blanket nimbyists' against all development (i.e. significant local concern being triggered on unsound information after planning permission had been secured.)

6. In our response to DETR on A way with waste, EWA recommended that the Environment Agencies should develop a policy statement to the effect that there is no regulatory or environmental reason why an EfW plant should not be constructed and operated if:

• it represent a component part of the identified Best Practicable Environmental Option;

• it complies with all relevant standards, Directives etc.;

• it satisfy all requirements for purposes of authorisation; and

• cumulative emission issues are satisfied (i.e. local background levels).

7. In our response to DETR on A way with waste, we highlighted that on account of the tendency towards more technically and financially complex waste contracts, a rapid escalation in tender costs had resulted. These costs add to the overall waste management costs in an unproductive manner. Furthermore, few companies can sustain such high levels of expenditure on a purely speculative basis and there is a real danger that market withdrawal could result, thereby reducing competition which would be against the very ethos of Best Value in the delivery of public services. In the worst case, extended public consultation could further exacerbate this situation.

8. EWA would welcome the opportunity to enter into early dialogue with the Agency as to how parallel tracking (for purposes of seeking planning permission and selected licence applications) can be developed. In an analogous manner to the provision of information under IPPC, it is imperative that streamlining mechanisms are considered that can assist in minimising the duplicating of information, saving time and reducing costs.

13. EWA is the recognised UK trade body representing the key developers and operators of EfW plants, together with leading players in the field including technology suppliers, environmental consultancies and the legal profession. The Association's membership includes major companies active in creating and implementing sustainable integrated waste management solutions covering all recovery options (recycling, EfW and composting.) The sector also plays an important role in developing thermal and material recovery solutions for non-hazardous wastes other than MSW.

14. EWA currently represents the UK EfW current installed capacity of 2.5 million tonnes/ annum of municipal and commercial waste. These energy from waste power stations, often described as incinerators., generate 200MW of renewable electricity. An additional 275,000 tonnes of EfW capacity is currently under construction with additional firm proposals (subject to planning) to increase total UK EfW capacity to c. 5.5 million tonnes. EfW plants sized as a component part of the Best Practicable Environmental Option also complement wider recovery targets by recovering ferrous and non-ferrous metals, and bottom ash as a secondary source of aggregate.

15. As a mature renewable energy technology, EfW plants will play an increasingly important role, together with other renewable technologies, in delivering Government's domestic renewable target. Implicit and inextricably linked with this commitment is the requirement to reduce the dependence on fossil fuels for electricity generation. EWA has estimated that the current generating capacity of the EfW sector displaces c.500,000t/a of non-renewable fossil-fuel alone in the form of coal equivalent. In addition, by displacing coal, in the order of 500 kg of non-renewable C02 are avoided per MWh generated. In instances where CHP represents a component part of the BPEO-selection for an EfW plant, the fossil-fuel and non-renewable C02 benefit will be substantially higher.

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