Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Annex 2


  1.  The Substitute Fuels Protocol[13] is non-statutory Environment Agency guidance governing the procedures for the permitting the use of alternative fuels within cement and lime kilns. It does not apply to any other industrial process.

  2.  This guidance supplements the formal legislative regimes-Integrated Pollution Control, currently being replaced by the Integrated Pollution Prevention and Control, the Hazardous Waste Incineration Directive and the forthcoming Waste Incineration Directive.

  3.  The Agency developed the SFP following recommendations made following two House of Commons Select Committee enquiries into the regulation of the cement industry and alternative fuels held during the mid 1990s. [14]

  4.  In view of developments in legislation since it was introduced, ie Integrated Pollution Prevention and Control, (IPPC), Hazardous Waste Incineration Directive, (HWID), Landfill Directive, and the Waste Incineration Directive, the use of alternative fuels is now much more rigorously controlled, and consequently the SFP has become superfluous.

  5.  The SFP is an inflexible regulatory tool that inhibits innovation and enforces continued reliance on less environmentally friendly fossil fuels

  6.  The SFP specifies the arrangements for public consultation and the technical requirements that operators must fulfil before they receive an authorisation. The latter include:

    6.1  Extensive trials before operators are allowed to burn the waste-derived fuel on a continuous basis. The Agency has set a minimum duration for these trials of six weeks. After completing the trials, operators will return to conventional fuel while the Agency carries out public consultation on the results;

    6.2  Detailed guidance on waste-derived fuel sampling, including guidance on methods and substances to be excluded from the fuels. No weight is accorded either to experience or the results of previous use of fuels at the same or other sites;

    6.3  More detailed guidance on emission sampling frequencies, calibration of instruments and analytical techniques, including a specification for the minimum number of valid results that must be obtained.

  7.  New procedures for extensive public consultation have been developed in the Tyres Protocol, see below.

  8.  The SFP guideline is structured in such a way that even after proactive public consultation and technical success of the trial, there is a break before progressing to permanent use of the fuel. At the end of the trial, the operator must stop using the fuel, reapply for its permanent use and undergo a similar period of public consultation and protracted technical determination. The authorisation may then be granted. The large time gap inherent in the protocol between trial and permanent fuel use also causes major contractual and logistical problems with potential suppliers.

  9.  A typical timetable for gaining permission to use fuels under the protocol is set out in paragraph 13 of the text.

  10.  Typically, the time involved in gaining permanent authorisation is 15 to 30 months. In addition the up-front costs of plant required to trial are £1 million to £2 million, with trial costs adding a further £600,000 to £800,000. All of these costs are essentially risk capital, which is forfeit if permanent permission is not forthcoming. These lengthy authorisation periods have a significant effect on the payback period. Delays between the end of trials and the granting of permits are problematic in terms of continuity of supplies (of alternative fuel to required quality standards) and operational conditions. [15]


Trial Costs:   
£150-250kEquipment for trial
£100-200kTrial supervision costs
£50kEvaluation of results
£50kStakeholder Consultation
£600-800kTotal, per location
Plant Costs:
For permanent use, plant cost are £1 million to £2 million

  11.  Once permission has been granted for the permanent use of an alternative fuel, considerable continuous monitoring and routine testing is incorporated within the Environment Agency permits, and is embodied in the Hazardous Waste Incineration Directive, such that any excursion from the limits imposed would be quickly ascertained, thus negating the need for the many aspects of the Substitute Fuels Protocol.


  12.  A separate protocol that controls the use of tyres has been issued recently[17] as a consequence of discussion between the Environment Agency and the industry over a period of two years. Although this provides a quicker route in granting authorisations for tyres than the SFP, nevertheless it imposes significant restrictions before tyres can be used as kiln fuel.

  13.  Whilst the resulting document is an improvement over the SFP; the constraints still applied to this "mature" alternative fuel are totally disproportionate in view of the proven environmental benefits of its use.

  14.  Furthermore, despite this "streamlining", the authorisation process in the UK still involves substantially greater preliminary trial work than elsewhere in Europe, where approval can take as little as two weeks, a typical time in Germany for an authorization to burn meat and bone meal. Even the traditionally "green" northern European states as well as France and Belgium—appear to operate on the premise that burning alternative fuels is environmentally beneficial and is to be encouraged. See Paragraph 13 in the text.

  15.  However, the UK cement industry would welcome the use of its procedures for stakeholder consultation as a model for the use of all waste-derived fuels across industry.


  16.  There is at present an imbalance within the UK in the level of scrutiny given to other industries burning alternative fuels, and far from gaining "first mover advantage" the cement industry has effectively been penalized as a result of its pioneering work in this area. For example: Coalite, Bolsover has been given permission to use tyres in its pyrolysis process. It obtained this permission without having to follow the either the Tyres or the Substitute Fuels Protocols. Implementation for them was quicker, cheaper and involved far less public consultation than for the cement industry.

13   Substitute Fuels Protocol for Use on Cement and Lime Kilns, Environment Agency. Back

14   "The Burning of Secondary Liquid Fuel in Cement Kilns"; "The Environmental Impact of Cement Manufacture", op cit. Back

15   Data from Lafarge Cement UK. Back

16   Tyres Protocol for Use on Cement Kilns: A Supplementary Note to the Substitute Fuels Protocol, The Environment Agency, November 2001. Back

17   Tyres Protocol for Use on Cement Kilns: A Supplementary Note to the Substitute Fuels Protocol, The Environment Agency, November 2001. Back

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