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Geoffrey Hillier
3nd April 2008
Plymouth City Council
Cabinet Members, meeting
April 8th 2008
Civic Centre
Plymouth
Councillors
Michael Leaves, Ted Fry, Peter Brookshaw, Grant Monahan, Dr David Salter,
Glenn Jordan, Vivien Pengelly, Delia Ford, Ian Bowyer, Kevin Wigens.
Mark Turner, Waste
Projects Commercial Manager.
Copy to: Councillor Tudor
Evans, Councillor George Wheeler
Secretary of State for
the Environment Hilary Benn MP, Alison Seabeck MP
Re: Plymouth City Council Cabinet meeting 8th
April 2008, Agenda Item 11, Future Waste Treatment – Outline Business Case
and Joint Working Agreement.
This open letter is sent
to the members of the cabinet meeting and concerns the proposed incineration
of Municipal Solid Waste (MSW) by Plymouth City Council.
The recent establishment
of an ‘Energy Park’ and the construction of a large gas power station at
Langage near Plymouth would lead a rational person to the assumption that
energy related installations would be sited with the new power station at
the ‘Energy Park’. In the case of the proposed Energy from Waste (EfW) and
related installations for the management of waste from Plymouth, West Devon
and Torbay the Langage site to the east of Plymouth close to the A38 and
near to the centre of the sources of waste would seem to be the natural
logical choice. The proposed EfW installation is described as ‘state of the
art’ and ‘iconic’ in design. It is bizarre that Ernesettle is the site most
favoured by Plymouth City Council, a mostly green field site which is
planned to be used for recreation, on the edge of the Tamar valley AONB, on
the west side of Plymuoth (the prevailing wind is from the west so Plymouth
housing is down wind of the site), only 200m from housing and schools
nearby, and furthest from the sources of all the waste to be treated. The
reason for Langage being rejected is that no agreement could be found to
site the ‘state of the art and iconic’ waste facilities at Langage because
it is a low grade operation which will not create enough high grade
employment. Consequently the choice of site for environmentally based waste
facilities is not being based on environmental considerations but on local
political differences.
Environmental
considerations have been put to one side and it is the environment,
sustainability and the City of Plymouth which are the casualties, and the
people of Plymouth and particularly the people of west Plymouth and
Ernesettle will have to live with this low grade waste operation or as some
describe it ‘a state of the art and iconic’ installation.
Although a planning
application will cover the detail of the proposed Energy from Waste (EfW)
facility the points which are raised here are environmental and
sustainability questions in relation to the principles of incineration of
Municipal Solid Waste (MSW) which concern:
1
the
waste stream and the contents of the ‘black bag’ MSW which is incinerated,
2
the
carbon footprint and sustainability of incineration of MSW and implications
for Plymouth
3
the
toxic and hazardous products of MSW incineration which are present in both
the flue gas emissions and the solid waste products of incineration (fly ash
and bottom ash) which is classed as hazardous waste,
4
the
use of Energy from Waste (EfW) and Combined Heat and Power (CHP) from EfW in
relation to the UK Government guidelines stated in ‘Waste Strategy for
England 2007’ and
5
the
sustainable alternatives to MSW incineration in Plymouth.
On 6th
February 2008 the Government Inspector Douglas Machin examined the Plymouth
Waste Development Plan Document (PCC Waste DPD).
On 21st
February I visited the ‘state of the art’ Southampton Marchwood EfW plant as
a representative of residents of St.Budeaux and Ernesettle, at the
invitation of the Government Inspector Douglas Machin together with
representatives of Plymouth waste planning department, and a Saltash
Councillor.
On 1st April
2008 the Government inspector approved the Plymouth Waste Development Plan
Document.
The following was written
after the Southampton Marchwood EfW visit on 21st February 2008
and has been
amended to take into
account the council cabinet meeting on 8th April, Agenda Item 11,
Future Waste Treatment – Outline Business Case and Joint Working Agreement.
1 The waste stream and income stream
The Southampton Marchwood EfW operation is tied to a steady stream of
‘black bag’ waste production. This huge installation at Marchwood needs
165,000 tonnes per annum (tpa) of ‘black bag’ MSW so that the council
receives its income, according to Richard Johnson, Commercial Director,
Veolia. The income stream is from the sale of 16MW of electricity generated.
Richard Johnson made it clear that the 165,000 tpa of MSW is needed every
year so that Hampshire Council gets the income from the sale of electricity.
The waste stream had become the income stream.
In the case of Plymouth
the EfW plant will be 37% larger than Marchwood burning 224,000 tpa MSW from
Plymouth, West Devon and Torbay. Clearly a constant waste stream will be
required to supply the Plymouth incinerator and households in Plymouth, West
Devon and Torbay will be required to produce enough ‘black bag’ waste to
feed the incinerator 240,000 tpa for 25 years, from 2014 to 2039.
Consequently there will be no incentive to reduce this ‘black bag’ waste
stream beyond the 2020 waste recycling target of 50% in accordance with the
‘Waste Strategy for England 2007’ and it is assumed by Plymouth City Council
that the quantity of waste per year will remain the same in the period 2020
to 2039. So from 2020 to 2039 there can be no reduction in the quantity of
MSW produced.
The ‘Waste Strategy for
England 2007’ does not state that after 2020 there should be no further
efforts made to reduce waste, and it is expected that further Waste Strategy
for England documents will impose further targets. The year 2020 is not the
end of ‘reduce, recycle and reuse’ and to many observers the 50% recycle
target by 2020 seems very low. This 50% target does not relate to the
quantity of waste produced per person. If climate change is to be taken
seriously then it follows that ‘reduce, recycle and reuse’ will have to
continue after 2020.
The Plymouth waste planners believe that any real reductions in MSW in
Plymouth, West Devon and Torbay will only happen in 1 or 2 generations, or
25 to 50 years. The planners believe that incineration of brown bin (or
‘black bag’) MSW is the way forward until at least 2039 and as the
incinerator will need the 224,000 tpa from 2014 onwards there will be no
incentive for Plymouth, West Devon and Torbay councils to significantly
reduce this level of MSW during the period up to 2039. If any party to the
agreement reduces the level of MSW stated in the April 8th 2008
Agenda 11, ‘Future Waste Treatment – Outline Business Case’, MT/Mar/08,
Table B then the income stream can not be maintained. If there was a
significant reduction in MSW by all the participant then the capital
structure set out in Outline Business Case (OBC) would become unsustainable.
The income from electricity is £35/MWh (April 8th 2008,
Agenda 11, Future Waste Treatment – Outline Business Case, MT/Mar/08,
Appendix C). The income/year is approximately £6million or approximately
£250 million indexed over 25 years. This income stream depends on 224,000
tpa MSW and in order to maintain this income stream the quantity of MSW can
not be allowed to reduce for at least 25 years until 2039. The waste stream
is to become an income stream to pay for the cost of the installation. There
can be no significant reduction in the MSW stream by Plymouth, West Devon
and Torbay from 2020 until 2039 because the income stream must be
maintained.
2 The carbon footprint
Incinerating 224,000 tpa
of MSW in Plymouth releases 224,000 tonnes of CO2* into the environment,
equivalent to the CO2 footprint from about 110,000 family cars** every year
for 25 years.
(*Incinerating 1 tonne of
MSW releases approximately 1 tonne of CO2 into the atmosphere.
**A small 1.4L family car
releases 150g CO2/km which is 2 tonnes/13,000km or approximately 2 tonnes
CO2/year. A heavy lorry produces approximately 1kg CO2 /km, or 13 tonnes
CO2/13,000km, ODPM figures 2002)
In addition there will be thousands of heavy lorry movements day after
day, week after week, year after year, for at least 25 years. Of the two
sites being considered in Plymouth for an EfW installation, Coypool and
Ernesettle, Ernesettle is the ‘Reference Project solution … most deliverable
site’ (April 8th 2008, Agenda 11, Future Waste Treatment –
Outline Business Case, MT/Mar/08, Paragraph 6.3,). Ernesettle is sited at
the furthest possible distance from all sources of waste so the heavy lorry
movements will be the maximum possible.
The casualty is clearly
the Plymouth environment and any future environmental aim to which Plymouth
may aspire, such as to be a low carbon or a zero carbon city, will obviously
become unachievable.
In addition the roads in
Devon, a popular tourist destination, will have the added burden of the
heavy lorry movements and the only route to Ernesettle is the A38 approach
to the Tamar Bridge which is often a bottleneck for traffic entering
Cornwall.
On all counts, the waste
stream, the carbon footprint, and the impact on Devon roads, this is a
completely unsustainable waste policy which is being proposed by Plymouth in
the Waste DPD over the timescale 2014 to 2039.
3 Energy from Waste (EfW) and Combine
heat and Power (CHP)
The use of Energy from Waste
(EfW) should follow the guidance stated below.
‘Energy from waste a guide to
opportunities in the UK’
Last updated: 28 January 2008
http://www.ukinvest.gov.uk/UKTI-publications/4024575/en-GB.html
‘Indeed, the Government’s
Waste Strategy for England 2007 requires significant reduction in the amount
of waste created, together with a substantial increase in the amount of
waste re-used and recycled. It requires the maximisation of the cost
effective pre-treatment of waste before disposal; and where disposal
requires combustion, that this is done in the most efficient way possible.
Combined heat and power (CHP) is the most energy-efficient process for
achieving this, the key outputs of EfW facilities usually being heat and
electricity. With CHP offering a significant improvement on a facility’s
carbon footprint as well as higher energy efficiencies, the CHP market in
the UK should see substantial growth.’
The reason for this
statement by the UK Government is that the high carbon footprint from
incineration of MSW can be offset by a high efficiency operation which uses
the heat from incineration not only to generate electricity but also uses
the waste heat for heating in industry or housing usually in the form of
District Heating (DH). It is an acknowledgment by the UK Government that
incineration adds to the CO2 released to the atmosphere and that the large
CO2 footprint must be mitigated by ‘offsetting’ or replacing energy from
another carbon based source of energy such as coal or oil. This is the UK
Government statement for maximising sustainability, a clear statement that
CO2 matters although it is expressed in terms of the efficiency of the
installation. It is clear that EfW installations must be sited where CHP can
be used. This statement is the UK Government’s response to climate change in
relation to EfW.
At Southampton Marchwood the incinerator is
located in a large industrial estate and at present CHP is not used.
Richard Johnson, Commercial Director VEOLIA, said on 21st
February that the connection was ready to be used. Richard Johnson explained
why CHP was not used at Marchwood (Appendix 1). Clearly part of the reasons
is technical relating the partial vacuum steam condition at exit from the
turbine and the power deficit which result from ‘pass-outs’, but also the
statement that ‘In Europe (meaning in other EU countries) the company
operates a number of these schemes’, which is a comment on the readiness to
make CHP work in other EU countries where the framework for high energy
efficiency is well developed. (Richard Johnson uses the term ‘district
heating’ which is a way in which waste heat can be usefully employed).
CHP installations are
common in many EU countries but the UK has not taken energy efficiency
seriously with the result that steam turbine installations have been
condensing in design whereas in many EU countries the turbines are high back
pressure with CHP in mind. Consequently the sitting of EfW for CHP is not
considered important by planners in the UK and the result is that an
unsuitable site such as Ernesettle is being proposed, instead of Langage
Energy Park where CHP could be used efficiently.
The waste heat available
from the Marchwood incinerator is of the order 21MW, approximately 16MW of
electricity is generated at 30% efficiency, 21MW or 40%* being useable waste
heat, and the total energy in the waste incinerated being approximately
53MW.
In the case of Plymouth’s
proposed incinerator approximately 21MW electricity will be generated and
the useable waste heat available is approximately 28MW being 40%* of the
total energy available.
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