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SITA incinerator plans. Presentation to Cornwall County Council 17 th September 2008. Objections/issues/concerns. Non compliance with the waste hierarchy Non-compliance with National Waste Strategy Non compliance with PPS 1 Planning and Climate Change supplement - PowerPoint PPT Presentation
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SITA incinerator plans
Presentation to Cornwall County Council
17th September 2008
Objections/issues/concerns
1. Non compliance with the waste hierarchy
2. Non-compliance with National Waste Strategy
3. Non compliance with PPS 1 Planning and Climate Change supplement
4. BPEO and Wastes Local Plan on which application is based is flawed
5. Lack of need for centralised incinerator
1. Waste Hierarchy
Source: Defra, 2008
1 The proposed incinerator is below the cut-off point for classification as “recovery”
Waste Incineration Directive formula for "efficiency“
energy produced - energy from fuels used - other energy imports X 0.97 (waste energy input + energy from fuels)
X 2.6 for electricity produced X 1.1 for heat produced
Total efficiency 57% Limit for consents 2009- 65%
Therefore application is for Disposal not Recovery
2. National Waste Strategy 2007
National targets for local authorities
recycling and composting of household waste:
40% by 2010, 45% by 2015 50% by 2020;
recovery of municipal waste: 53% by 2010, 67% by 201575% by 2020.
Local targets with incinerator recycling and composting of household waste:
recovery of municipal waste:
year National Cornwall
2010 40% 31%
2015 45% 47%
2020 50% 47%
year National Cornwall
2010 53% 31%
2015 67% 47%
2020 75% 47%
o Non compliant with Waste Strategy 2007
3. PPS 1 : Planning and Climate Change Supplement
“planning authorities should have regard to this PPS as a material consideration which may supersede the policies in the development plan”
To meet PPS1 requirements …. the proposal should at the very least provide a reduction in carbon emissions compared to the present situation”
Flawed calculation by Sita on CO2
Incinerator vs. Landfill
1. Uses incorrect figure for carbon saved from electricity produced
2. Does not compare carbon on the same basis for the two options
3. Their transport calculation ignores lorry return journeys
GHG conversion figures
The 524g CO2/kWh used is incorrect for replaced fossil electricity
Defra clearly state that this figure should only be used for short term measures. eg low energy light bulbs
The figure of 430 g/kWh for long term is a more representative figure ……….When calculating emissions reductions based on long term investment decisions …companies should use this factor.
ie Sita overstate savings on this by 22%
Source: Guidelines to Defra's GHG conversion factors for company
reporting, 2007
Emission source tpa CO2e Incinerator Landfill
Emissions 190,474 48,593
Avoided emissions
Total avoided 72,372 120,544
Net emissions 118,102 13,768
Incinerator worse by 104,334
However
Sita say -36,611 49,070
Sita say incin better by 85,700
Comparison of GHG emissions for incinerator & landfill options, calculated on an equal treatment basis
Incinerator worse by 4.75 million tonnes CO2e over 25 years
GHG emissions conclusion
Incinerator worse by 4.75 million tonnes CO2e over 25 years
ie 190,000 tpa CO2
or
Four times CO2 emissions from all CCC activities
or
14% of Cornwall’s travel CO2
Saying yes to the incinerator
says no to all climate change policies
4. BPEO and Waste Local Plan
WLP based on BPEO Inspector passed WLP in 2002 as the Waste
Strategy promised. Not yet prepared: therefore no major push for recycling
Example error in BPEO : Anaerobic Digester option: Major flaw in the BPEO report reduces income from
AD plant by three quarters Assumptions invalidate the positive environmental
credentials of AD for 10 factors by 2-100 times 2nd BPEO report in 2001 enabled CCC to ignore
major potential for AD errors in this BPEO so bad government changed the
methodology to SA
5. The lack of need for a centralised incinerator
The case for the incinerator is based on the BPEO flawed document
Transport analyses show little difference in the amount of travel required to feed 1, 2 and 5 incinerators
wrong 400,000 miles pa lower for 3 plant The 5 sites option is based on all 5 being the same size
requiring extra waste trucking poor choice of option (deliberate?)
ERM 2008 facilities analysis is biased to the single
incinerator and hence reaches invalid conclusions based on inaccurate key assumptions
5. The lack of need for a centralised incinerator
Sita are now progressing small plant
e.g. planning application submitted for 60,000 tpa oscillating kiln w-t-e plant to Telford and Wrekin Council
cleaner technology (could be better) smaller footprint higher capital cost, but faster build, saves LATS
A more sustainable way forward
Three local sustainable technology sites better:- Transport savings of £3.6m pa 400,000+ lorry miles pa saved Increased local heat sales so GHG savings > 20k+ tpa Reduced local objections by providing local benefits
(employment and heat) reduces the health impacts at St Dennis, a material
consideration for planning. Total increased GHG savings of 22,000 t CO2 pa
A more sustainable way forward
Local waste treatment using sustainable technologies ensures:
• local choices of suitable technology eg AD, MBT, etc
• local responsibility
• local respect
• local employment
• lower pollution
• lower transport impacts
• quicker build 1-3 years not 4-5 years
• more flexibility in changing times
A more sustainable way forward
Example gasification plant for 275,000 people
Comparing options £m
Incin Decentralised
Gasification MBT + compost
MBT + AD
Capital costs 117 106 50 65
Op costs pa 12 14 12 11
Income pa 13 20 1 3
Net income pa -2 6 -11 -8
Tax/LATS-2020 207 197 131 131
Total net costs to 2020
456 372 271 258
Savings over incin to 2020
0 84 185 198
Conclusions
five major policy reasons to refuse saying yes to the incinerator says
no to all climate change policies the decentralised options are
cheaper for the Council so cost concerns can be discounted
developing a decentralised Waste Strategy first will reap dividends in local acceptance