Bold position

Luke Prazsky, Service Director – Waste Resource Management, Wardell Armstrong, looks at the reasons for the refusal of planning consent for Wheelabrator’s proposed Kemsley North energy from waste plant, and asks what do they mean?

I was very interested to read comments attributed to the secretary of state, Kwasi Kwarteng, following the planning refusal of Wheelabrator’s proposed new energy recovery facility, Kemsley North, whilst an existing adjacent facility, also a Wheelabrator facility, was granted planning consent to increase its annual throughput.

It was widely reported that he agreed that the new plant could impact recycling rates and he also criticised it for not being energy efficient. For the approved capacity increase Mr Kwarteng pointed to “a greater benefit as a result of its better Combined Heat and Power performance”, reinforcing the importance of securing a heat offtake for new Energy Recovery Facilities.

Whilst the Environment Agency has seen fit to issue an environmental permit, the comments by Mr Kwarteng strike me as potentially significant and could have ramifications for other new potential energy recovery facilities in addition to blurring lines between planning and environmental permitting.

Mr Kwarteng’s comments appear to signal a clear government position that energy recovery facilities do impact on recycling, which is a bold position for a government to take, and one that I would strongly counter. Secondly, his comments on energy efficiency seem to be going above and beyond recognised (and published) best practice that industry works hard to meet.

Do Energy Recovery Facilities really impact on recycling rates?

Whilst there has long been this argument, it is my opinion that there are factors at play that prevent this hypothesis from becoming reality and mean energy recovery facilities don’t impact on recycling rates. Put simply, recycling rates are impacted by two things: socio-economic factors and the recycling provisions made by local authorities, including education and promotion.

Householders do not make a decision on what to put out for recycling based on whether the item in question might be sent for energy recovery or landfill if not recycled. It comes down to how easy it is to separate and store material streams for recycling, the extent and convenience of the recycling service offered by the local authority, their awareness of recycling and their desire to want to recycle. These are not affected by whether their local authority sends residual waste to an energy recovery facility or a landfill.

Commercial and industrial waste producers are legally obligated and financially motivated to apply the Waste Hierarchy to their waste streams, which includes not producing waste in the first place and finding alternative uses for wastes (re-use) or maintaining value in the material as per the circular economy model. This will be further enhanced through the Enhanced Producer Responsibility requirements that will focus manufacturers on improving product recyclability.

Will incineration tax boost recycling?

And let’s not kid ourselves, the likelihood of an incineration tax is high. Whether that actually drives further recycling increases will be influenced by market economics (the price for material streams) or whether new and alternative technologies can step in to fill the gap, alongside producers developing more products with greater ease of recyclability.

I firmly believe that energy recovery facilities have an important part to play in achieving a circular economy because they realise the remaining value in non-recyclable residual waste, which, I accept, would be further optimised when combined with a heat offtaker. The incineration tax will need to fuel an increase in the value of residual waste and whilst also driving a reduction in tonnage to effectively deliver its goal.

What is good energy efficiency and should planning make that call?

Combined Heat and Power (CHP) allows a greater amount of energy to be recovered from residual waste through the export of heat and electricity, rather than simply electricity alone.  You can see why it is important to aim high. And that is to be delivered through the Energy Efficiency Directive, the implementation of which is tasked to the Environment Agency.

The very same Environment Agency has just issued an environmental permit for the proposed facility which means they accepted that the proposed energy efficiency is acceptably high in line with recognised best practice – the Waste Incineration BREF (Best Reference) Note was only updated in December 2019. I honestly can’t tell if the goalposts have moved. If you ask the Environment Agency, they will quite rightly point to the revised BREF Note but if the government is going to move the goalposts it should at least tell the environmental regulators!

If the planning decision is going to set a precedent for energy efficiency does this mean that heat users are going to have to be secured at the same time? How deliverable will that be? It has always been a classic case of chicken and egg with heat end users but in more cases than not the ERF comes first and then attracts a heat demand.

I don’t know how the planning system can ensure an end user for the heat will be secured unless the same applicant is going to construct (or at least be engaged with the development of) both the ERF and a facility that can effectively use the heat. We might as well introduce a policy for growing pineapples or avocados at every new ERF! Whilst I may joke, there are actually some great carbon balancing opportunities from ERFs who can supply heat and carbon dioxide to greenhouses. Brexit might actually present an opportunity in this regard.

Finally, if the planning decision is going to set a precedent for energy efficiency, because the larger ERFs can offer this, does this mean that we are only going to be seeing consent for ‘super ERFs’? This might not be the best option where there is not a local/regional need for such a large facility. What happens then? Landfill or the transportation of waste over a considerable distance? That’s not a good result in my book.

So, in conclusion, I can only find the secretary of state’s reasons to be well intentioned but ultimately ill-informed, please can we see this decision challenged and dismissed.

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