Select Committee on European Communities Eleventh Report


101. No reliable prediction has been provided to us of the additional incineration capacity needed across the EU in order to meet strategic waste management objectives and the requirements of the Landfill Directive. This is a key question for the UK national waste strategy. The DETR has estimated that between 28 and 165 new incinerators (over and above the 10 currently in operation) would be needed in the UK to meet the targets of the Landfill Directive (see paragraphs     Ms Ruth Frommer, for the Commission (DGXI), said that mere incineration of waste, like landfill, was a form of disposal; as such it was the least preferred option in the Community's waste management strategy, in which the first option was to prevent waste, the second being to recover materials and energy from waste and disposal coming last (Q493-6). Mr Meacher agreed that incineration should be seen as one of a range of waste management options, but said that the Government was still keen to see a big increase in recycling. He added, however, that to meet the requirements of the Landfill Directive "there is no question that there is going to have to be some significant increase in incineration. The size of it I think is quite alarming" (Q451). Asked to explain the basis of his Department's estimates of additional incinerator capacity needed, he said that the estimates were essentially based on estimates of future waste arisings on a number of different recycling scenarios (Q470).-   The Minister later expanded on this and other points in a letter (p118). The figures of between 50 and 177 new incinerators which he quoted in his oral evidence have been revised downwards to between 28 and 165 on the basis of an updated Regulatory Impact Assessment (RIA) for the Landfill Directive, provided to Parliament with a Supplementary Explanatory Memorandum (7161/99) of 16April 1999. The calculations assume incinerators with an average capacity of 200,000 tonnes of waste per year. It is estimated that capital investment of between £1.4 and £6.9 billion would be required by 2016 to meet the targets of the Directive, depending on the assumptions made about the level of recycling and use of other waste management options. Extracts from the RIA are reproduced in Appendix4.). In our view, this is a wholly unsatisfactory basis on which to plan. We have been offered no indication where these plants might be sited or their capacity, apart from the assumption that their average capacity would be 200,000 tonnes per year. We do not know what sources of investment funding would be available. Would existing operators in the field have the resources for such a major expansion? Or would it require public sector input, perhaps through public-private partnership (PPP) funding? We find it inconceivable that, without direct government intervention, as many as 165 plants would ever receive planning permission within the timescale required by the Directives.

102. As we have already suggested, a combined effort by the UK Government, the devolved national administrations, local government and the waste management industry is necessary for developing co-ordinated national and local waste strategies. Clear guidance must be provided to the waste management industry and to local government on relevant criteria for the siting of incinerators. The strategy must be supported by firmer predictions of the number of new incinerators required and by guidance on the means for identifying the geographical areas that they will need to serve, so as to inform the process of planning and public consultation at the local level. It is also essential that proper estimates are made of the resource implications for the national regulatory agencies and local authorities, whose inspectorates already work under considerable pressure.

103. With or without the present proposals, there will need to be a substantial increase in investment in incineration in order to meet the targets of the Landfill Directive. The fact that new incinerators will have to meet more stringent emission limits is not in itself a serious barrier to investment. However, robust, transparent and publicly acceptable long-term waste management strategies are essential if the private sector is to plan for the necessary investment. At present the greater obstacles lie not in the regulatory regime but in piecemeal strategic planning and lack of public commitment.

104. In carrying out such planning, it is critical to form reliable estimates of what is achievable through waste minimisation, recovery and recycling, and the likely rate of progress. Otherwise it will be well-nigh impossible for incinerator operators to plan new investments, since in effect they are looking for guarantees of sufficient supplies of waste to enable them to work to capacity for up to 20 years or more. Experience in Germany suggests that it is the success of recycling policies that has led to many waste incinerators now working below capacity and therefore (in commercial terms) at a loss. However, North American experience indicates that where it is part of a planned and integrated waste management strategy, waste incineration can co­exist with, and support, high recycling rates.[27]


105. Obtaining energy from waste incineration—whether through the provision of heat or through electricity generation or a combination of both—is a form of renewable energy (the subject of a concurrent enquiry by Sub-Committee B) There is prima facie scope for increased provision of combined heat and power (CHP) from waste incineration in the UK; we are however concerned that an over-prescriptive approach (as contemplated by the Rapporteur to the European Parliament's Environment Committee) could be counterproductive and even inhibit waste minimisation and recovery. On the other hand, without the benefits of CHP, incineration may not be the BPEO for disposing of wastes from which value cannot be found in other ways. This will however depend heavily on the siting and sizing of incineration plants, and on the level of public acceptance of plants locally.

106. The UK has a poor record in CHP generally. In its particular application to waste incineration, difficulties arise not least because of the problems which the private sector faces in promoting schemes in conjunction with industrial development and housing projects, whether public or private sector. The Government should give increased encouragement to the use of CHP. This, we recognise, will call for imagination and innovation. There will be scope for PPP funding, but also additional credit approvals—or even subsidies—to local housing authorities may be needed.

107. We were interested to be told by Commission officials that in Norway there is an established, and publicly acceptable, market for small incinerators of between 18,000 and 36,000 tonnes annual capacity for providing district heating to small rural communities.[28] Whilst conditions in the UK will not everywhere lend themselves to such solutions, we think it is a mistake to base planning exclusively on incinerators in the 200,000 tonnes range. We recommend that the scope for investment on this smaller scale should be explored by local and central government in parallel to the planning of facilities serving larger urban or regional areas.


108. We have already drawn attention in paragraph 0 to the serious limitations of the Government's Regulatory and Environmental Impact Assessment and the underlying consultants' reports as far as health impacts are concerned. Whilst having some reservations about the more alarming scenarios that were put to us in evidence, we nevertheless consider it is particularly necessary to apply the precautionary principle in this field. We are satisfied that the tightening of emission limit values through the draft Directive is an appropriate response. In particular, the Commission's estimate that the proposals would have the effect of reducing incinerator emissions of dioxins and furans in the Community to less than one hundredth of their present levels is reassuring.

109. The potential health impacts of incineration emissions have been a source of concern to a number of interest groups and to sections of the general public, particularly members of local communities concerned about the siting of new plant in their neighbourhoods. Evidence to the enquiry tended to concentrate on the generic toxicological effects of the various chemicals. No evidence, however, was supplied of any scientific proof of a direct causal link between any incineration plant in the UK and local mortality or morbidity. We are aware of a number of studies which have reported apparent clusters of different carcinogenic effects in the vicinity of particular facilities in the UK, Europe and North America, but there has been no evidence that the incinerators concerned were the cause and there has generally been considerable difficulty in isolating causal links from general environmental sources. As Professor Clayton noted, such studies have related in the main to older incinerators prior to upgrading and to others which were no longer operating.

110. Nevertheless, when the precautionary principle is applied, we think it would be wrong to discount public concern about the health implications of incineration products (especially dioxins) on the grounds that it is derived from the experience of an older generation of municipal incinerators which the 1989 Directives have essentially done away with. Although considerable progress has been made in the understanding of the toxicology and exposure effects of many of the key pollutants, continued epidemiological work will be needed. We consider that there are well-established grounds for caution, justifying the general approach of the draft Directive. We feel that the collection and study of data on the potential health risks from combustion products should continue to be a priority. In particular, in the light of the evidence from health professionals about emissions of particles of ammonium nitrate below PM2.5, and their behaviour in the body, we welcome the further research that is being conducted in this area. At the same time we think it is important that attention should not be focused disproportionately on the health risks of incineration. There is an urgent need to improve our understanding of the health risks arising from other waste management options, including recycling, composting and landfill.


111. It has been suggested in evidence that there is a need to ensure that development control and IPC authorisation procedures consistently address the potential health impacts of proposals for new incinerators. Although risk assessments have increasingly been undertaken as part of the planning application and environmental assessment process, there is no formal encouragement to this. The Waste Incineration Directive could usefully echo the terms of the Environmental Assessment Directive, in order to make it clear that the "impacts on humans" of a proposed incinerator covers health impacts. The WI Directive should require local health impact assessments to be made for all proposed new incineration plant.

112. A deficiency of the EA Directive is that it provides for no formal link between approval and post-operational environmental monitoring. To do the latter effectively, it is necessary to collect data on maximum ground level concentrations of pollutants in the environment surrounding the incinerator; stack monitoring is insufficient for this purpose. The footprint of ground level concentrations will vary from plant to plant and according to topographical and meteorological factors. We understand that SELCHP voluntarily monitor concentrations at 1 Km distance from the plant.

113. UK guidance on environmental assessment should provide clearer support to local health impact assessments, which should take into account baseline health conditions in local areas as well as prediction of health risks arising from the emissions from new incinerators. In turn we consider that all plant authorisations should require monitoring of local environmental impacts, on a case-by-case basis tailored to local circumstances.


114. We are concerned that the links between pollution control and public health management are not being systematically addressed; there is a lack of clarity over where the primary responsibility lies. The Environment Agency, SEPA and EHS (DOENI) admit that they depend on external expertise to perform their required functions in assessing the potential impacts of waste incineration on human health. Bearing in mind the agencies' responsibilities under Part I of the Environmental Protection Act 1990 and related legislation we find this disquieting. The Memorandum of Understanding between the Environment Agency and the Department of Health provides for consultation, but we were not convinced that there was an effective flow of information at the "sharp end"—i.e. between local staff facing actual situations on the ground. We recommend that consideration be given to introducing a statutory consultation role for the Department of Health and its counterparts.


115. The proposals in the draft Waste Incineration Directive, especially if linked to the standards of the Hazardous Waste Incineration Directive, have the potential to play a significant role in reassuring the public that incineration is a safe environmental option. However, this will only happen if the public has confidence in the regulatory regime through being involved in the process of planning for new capacity, in the ongoing operation and monitoring of the facility, and in the monitoring of the surrounding environment. The availability and accessibility of environmental information, as provided by the regulators, is not a sufficient solution to public scepticism. Original figures need to be translated into readily comprehensible form, and politicians at the local, devolved and national level must show that they themselves understand the basic scientific issues, and are able to express them in terms that their constituents understand.

116. Land-use planning constraints on the siting of new incineration capacity have the potential to lead to the choice of socially deprived and environmentally damaged areas. These tend to be areas with high existing levels of industrialisation mixed with poor quality housing. We consider that not only is there a need for sound environmental impact assessments (EIA) of proposals for new plant, but also that these should be based on strategic environmental assessment (SEA) of the national and local strategies which underpin the siting. The reluctance of successive UK Governments to pay more than lip service to the principle of SEA, including the proposed Directive of which the latest version is currently on the table[29], is a matter of continuing disappointment to us[30] (although we note that a form of environmental appraisal is addressed in guidance on development plans). We recommend that the Government should now resolve to support and encourage SEA for waste policies and plans; we further recommend that both SEA and EIA should be undertaken with the fullest involvement of the public.


117. The Committee considers that the Commission's proposals for a Directive on the Incineration of Waste raise important questions to which the attention of the House should be drawn, and makes this Report to the House for debate.

27   Information from the Specialist Adviser. Back

28   QQ 533-5. Back

29   COM(99)73 final, 18 February 1999. Back

30   House of Lords Select Committee on the European Communities, 11th Report, 1997-98, Correspondence with Ministers, 20 January 1998, HL Paper 60. Back

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