After Defra’s response to a call for evidence about the RDF market, FCC Environment’s sales and marketing director, Kristian Dales, argues that government intervention in the RDF market could create unnecessary barriers, increase costs and artificially distort the market. CIWM Journal Online Exclusive
We welcomed Defra’s call to evidence about RDF in March this year and submitted our insight as an RDF producer and operator of three EfW facilities (with two additional plants under construction). From our experience, the Environment Agency should increase the monitoring and policing of the RDF market using existing powers and the permitting system to clamp down on illegal activity which discredits the sector. However, too much governmental intervention could damage the viability of the market.
There is a shortage of EfW treatment capacity in the UK, whilst there is overcapacity in Europe due to decreasing tonnages of residual waste. Low shipping costs and the current strength of sterling make exporting RDF less expensive and more environmentally suitable than landfill disposal. More EfW capacity is currently under construction or planned in the UK and these facilities, once they become operational towards the end of the decade, will compete against exporting opportunities for RDF.
RDF offers both local authorities and businesses a cost effective treatment and disposal method for residual waste which is fully compliant with the waste hierarchy and diverts waste from landfill. Detractors of RDF highlight that some recyclable materials remain in residual waste which is processed at RDF facilities. However, it does not make economic sense to remove these materials (unless they are metals) as the process is expensive and the resulting recyclate would not meet reprocessor specifications due to high levels of contamination.
“Too much intervention should be avoided as this would increase financial burdens on the RDF market. The Government should work with the industry to make sure that a balance is achieved…”
The Department has stated that it will consider introducing a treatment specification for RDF to tighten the recovery criteria. It is our belief that intervention from the Government will only increase RDF production costs (which would cost businesses and local authorities more) and reduce the viable opportunities for export, contrary to free trade principles across the EU
The high costs of RDF production, landfill disposal and the PRN system already provide sufficient reasons to recycle as well as recycling targets. In addition, TEEP guidance requires all local authorities and businesses to collect recyclable materials according to what is technically, environmentally and economically practical.
An RDF standard would not make sense as European EfW facilities vary so operators should be able to define their own RDF specifications. What would be the point of producing RDF without an identified end user? A standard specification would also be difficult to implement and police. Luckily, common sense has prevailed and Defra will not introduce a composition standard for RDF. This will be left to the receiving EfW plant operators to set as it should be.
We support Defra’s commitment against banning or taxing RDF exports. There should also be no artificial constraints on the number of RDF production facilities or tonnages produced or exported. Limitations would inevitably lead to a reversal in the UK’s declining use of landfill as a residual waste disposal method until at least the end of the decade when more EfW facilities are built and become operational. However, it is shame that there won’t be subsidies to encourage investment in EfW infrastructure in the UK and create a domestic market for RDF.
The Department’s emphasis on clamping down on waste crime in the industry should be applauded. We advocate the Environment Agency exercising its existing powers to a greater extent to police the production, storage and use of RDF. All storage of RDF should be controlled under an environmental permit with appropriate limits on production facilities and ports.
Well wrapped and strapped bales can be stored for several weeks without causing any environmental nuisances but a maximum period should be recommended. Storage limits would prevent the dubious practice of stockpiling RDF in the hope the market improves as some operators use this to avoid the cost of disposal, creating a short term benefit in cash flow.
Defra has listened to the industry on the whole, particularly in its vow against setting a compositional standard for RDF and hard line against waste crime. However, too much intervention should be avoided as this would increase financial burdens on the RDF market. The Government should work with the industry to make sure that a balance is achieved so that residual waste continues to be diverted from landfill and energy is recovered from the treatment process.