Select Committee on Environmental Audit Memoranda


Memorandum from the Environmental Services Association (ESA)


  1.  Inclusion—preferably full inclusion—of electricity generated from waste is required in the Renewables if the challenging target for generation of electricity from renewable sources are to be delivered.

  2.  Energy from waste is still insufficiently commercially viable to be excluded from the Renewables Obligations. In particular, exclusion would hinder the development of new and emerging electricity generating technologies in their application to waste.

  3.  A higher contribution by electricity generated from waste is consistent with the ambitious recycling targets and other objectives of the National Waste Strategy.


  4.  The Environmental Services Association ("ESA") welcomes the opportunity to comment on the above titled inquiry as the sectoral trade association representing the UK's waste and secondary resource management industry, a sector contributing more than £4.0 billion to the UK economy (about 0.5 per cent of GDP). Our Members provide integrated solutions to waste across the full spectrum of thermal, biological, mechanical and physico-chemical treatment and processing options, and are consistently achieving more sustainable waste management practices.

  5.  We commend the commitments made by the Government to create an improved climate for electricity generation from renewables, and to support it for 25 years in terms of the Renewables Obligation. Current over-reliance on fossil fuels is unsustainable in terms of its depletion of irreplaceable natural resources and the growing evidence of negative environmental impacts. Delivery of the Kyoto Protocol is predicated on a de-coupling of carbon-intensive energy consumption from economic activity and growth.

  6.  For instance, ESA would like to draw the Committee's attention to the conclusion reached by the Royal Commission on Environmental Pollution in its study on energy and the environment[39] when it warned of catastrophic consequences if the United Kingdom did not adopt a strategy to reduce carbon dioxide emissions by 60 per cent from present levels by 2050.

  7.  As the leading UK trade association for the waste management and evolving secondary resource management industry, ESA is committed to supporting measures that contribute positively towards achieving sustainability.

  8.  However, we believe that exclusion of energy from waste from the Renewables Obligations would invite failure in delivering 10 per cent of the UK's electricity supply from renewable sources. This is despite Government accepting that energy from waste is a renewable source of energy.

  9.  In both the conclusions document in response to the public consultation on new and renewable energy[40], and the UK's National Waste Strategies, the Government (together with the devolved administrations) clearly stated its recognition of the role of energy from waste in the delivery of key international, European and national policies for energy, waste and the environment. ESA believes that electricity generated from non-hazardous waste, as part of an integrated waste management strategy, represents a significant step towards the Government's proposed programme to tackle climate change, and to encourage a more sustainable approach to energy generation and wider sustainability objectives.

  10.  ESA believes that the Government should be doing its utmost to use the Renewables Obligation to encourage as much electricity generation from renewable sources as possible rather than discriminating between different sources.


  11.  Delivery of 10 per cent of the UK's electricity requirements from renewable sources by 2010 will be extremely challenging, requiring the development of a complementary renewables portfolio of proven and near-market technologies. No renewable technology can or will deliver in isolation.

  12.  If the intention of Government is to use the Renewables Obligation to reduce carbon dependency, ESA believe that there should be the inclusion of as many different sources as possible. We are therefore disappointed-and surprised-that the DTI plan to exclude energy from waste from the Renewables Obligation in England and Wales. However, we support the rational decision of the Scottish Executive to consult on this issue, rather that dismissing it out of hand.

  13.  ESA is gravely concerned that the Government's blanket intention to exclude electricity generated from the combustion of suitable, non-hazardous wastes from the Renewables Obligation is based on the unfounded premise that this technology is "sufficiently commercially viable to allow us to concentrate support on those renewables which have yet to reach this stage[41]." Paradoxically, the Government has acknowledged that energy from waste will have an important role to play in meeting the 10 per cent target.

  14.  ESA believes that Government has significantly over-estimated the commercial strength of energy from waste and we are unaware of what criteria has used to define "commercially viable".

  15.  In order to compete effectively with other sources of electricity, energy from waste must (currently) rely on the economies of scale from the operation of larger plants. To date no new energy from waste plants have been commissioned under the last two NFFO tranches (IV and V) and therefore the viability of energy from waste under the present market conditions remains unproven.

  16.  Uniquely amongst renewable technologies, the generation of electricity from waste—whether in existing proven technology (ie mass-burn and fluidised-bed) or near-market technologies (eg gasification, pyrolysis and anaerobic digestion)—does not merely compete in the electricity generating market, but also depends on a waste contract. Consequently, exclusion from the Renewables Obligation would mean that the costs of energy from waste being converged with the costs of the other energy sources could only be achieved via higher gate fees on the waste contracts. Added to this are the higher costs associated with the development and implementation of new thermal technologies such as gasification and pyrolysis. Despite the forthcoming implementation of the Landfill Directive and the introduction of a statutory performance target for recycling and composting, current indicators suggest that landfill will remain the cheapest waste management solution for over two thirds of municipal waste for the next 10 years.

  17.  Indications from Government tend to suggest a preference towards smaller capacity energy from waste facilities. Whilst our Members can deliver smaller facilities, this prevents the development of economies of scale thereby causing gate fees per tonne of waste to increase and rendering energy from waste significantly less competitive in both the waste management and electricity markets.

  18.  In such a climate, the contribution of energy from waste could be extremely limited. For example, financiers have indicated a lack of willingness to provide funding to energy from waste projects if the technology is excluded from the Renewables Obligation—indeed banks see higher risks under NETA due to "balancing and settlement" risks and Supplier credit risk. Without this investment security and minimum contract periods of 10 or 15 years (between Generators and Suppliers), industry will have insufficient confidence to invest to bring on stream an additional 7TWh (18.4 per cent of the total renewable energy target), overwhelmingly from energy from waste, by 2010 as called for in the DTI's recent consultation[42].


  19.  The Government's vision for the achievement of the 10 per cent target by 2010 includes a projected increase in the generating capacity of energy from waste from the current capacity of 1.5 TWh to 7 TWh. To deliver this extra capacity, which the Government currently proposes to exclude from the Renewables Obligation, would require an additional 12.9 Mt/annum of generating capacity from waste (in addition to the existing 2.7 Mt). Based on 1998 figures of 27Mt of municipal solid waste (MSW), this would require diversion to energy from waste of almost 58 per cent of arisings. However in reality the overall percentage of MSW required would be reduced, by taking into account the contribution from suitable non-hazardous commercial and industrial fractions, diverted to energy from waste. If MSW arisings were to grow at the commonly accepted rate of between 1 and 3 per cent per year by 2010, a reduced level of diversion to various waste to energy generating technologies of between 33.5 and 42.4 per cent of projected MSW arisings by 2010 would probably be required.

  20.  At present the UK has about 500MW of electricity generating capacity from non-hazardous waste (approximately 60 per cent from landfill gas and 40 per cent from energy from waste power stations). These facilities operate according to strict standards laid down in European Union legislation and are tightly regulated by the competent authorities.

  21.  The current political climate tends to suggest that smaller scale energy from waste plants are "socially preferable", irrespective of any net environmental benefit. If the position across the UK is the same as that proposed by the GLA for London (ie calling for any future energy from waste capacity to be limited to 100,000 tonnes/annum per plant) then a further 129 energy from waste plants would be required by 2010. This would require as many new plants being commissioned each year (and for the next ten years) as already exist in the UK. ESA believes that such a level of growth in energy from waste capacity vastly exceeds the expectations of the UK waste management industry and the Department of the Environment, Transport and the Regions. The basis for these assumptions is summarised in Table 1.

  22.  The experience of ESA Members is of a planning system that is inefficient and slow to deliver, and the long lead-time for facilities to be commissioned (typically six to eight years from concept) will therefore prevent energy from waste from fulfilling the Government's expectations. To exclude energy from waste from the Renewables Obligation would further exacerbate this situation. If smaller scale thermal processing capacity (such as anaerobic digestion, gasification and pyrolysis) are to feature prominently in the future, the overall number of planning permissions required could be between 200 and 400. However these new and emerging technologies, in their application to waste, are still in their infancy. ESA can provide detailed examples of where the planning system does not deliver if the committee were to find this helpful.

  23.  Problems with the planning system are not confined to more contentious technologies involving energy from waste. Indeed, the planning authorities in Wales referred a proposal to build what would have been the UK's largest wind farm in Cefn Croes near Aberystwyth, to the DTI as recently as January 2001. Faced with an inflexible system that is unable to deliver even those technologies perceived as "deep green", the chances of the Government realising its 10 per cent target by 2010 are slim.

  24.  In recent months there has been much sensationalist media coverage on the future role of electricity generated from waste in the delivery of renewable energy targets, and its role in the National Waste Strategy. This has focused entirely on perceived impacts. However all economic activity, including waste management, brings environmental impacts. ESA is most concerned that there is very real potential for total paralysis in the planning process for applications for all renewable energy infrastructure, if sensationalist media coverage is allowed to drive the debate.

Table 1


Contribution from non-eligible sources (TWh)
Additional energy from waste capacity1 (Mt/year)
New Plantsat 100kt

  1 1 tonne MSW is taken as being required to generate 550 KWh electricity ie 1.82Mt MSW are required to deliver 1TWh electricity. The current contribution from energy from waste plants is in the order of 1.5 TWh.

January 2001

39   Royal Commission on Environment Pollution. (2000). Energy-The Changing Climate. London. The Stationary Office. Back

40   Department of Trade and Industry. (2000). New and Renewable Energy: Prospects for the 21st century: Conclusions in Response to the Public Consultation. London. DTI. Back

41   Department of Trade and Industry. (2000). New and Renewable Energy: Prospects for the 21st century: The Renewables Obligation Preliminary Consultation. London. DTI. Back

42   Department of Trade and Industry. (2000). New and Renewable Energy: Prospects for the 21st century: The Renewables Obligation Preliminary Consultation. London. DTI. Back

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