UNITED KINGDOM WITHOUT

INCINERATION NETWORK

Application by Peel Environmental for Off Eakring Road, Bilsthorpe

PINS Ref: APP/L3055/V/14/3001886 Application No: ES/2950

INTERESTED PARTY

COMMENTS ON EUNOMIA'S JUNE 2015 RESIDUAL WASTE INFRASTRUCTURE REVIEW

"Development of the Bilsthorpe Energy Centre to manage unprocessed and pre-treated waste materials through the construction and operation of a plasma gasification facility, materials recovery facility and energy generation infrastructure together with supporting infrastructure"

6th October 2015

UKWIN June 2015 Residual Waste Infrastructure Review for Appeal Ref: 3001886 1

Introduction

1. UKWIN noted, at Paragraph 8.3 of our Note to the Inquiry on the Main Issues Set

Out By the Inspector at the Pre-Inquiry Meeting dated 9th July 2015 [IP9], that:

"UKWIN may make a further submission on the lack of need for the proposed

gasification facility and potential adverse impacts in relation to the Waste

Hierarchy. This submission would draw upon new information such as Eunomia's

latest Residual Waste Infrastructure Review (the 8th Issue was released on 22nd

June 2015, and the 9th Issue is expected to be released in late November 2015)

and upon details regarding the emerging European Circular Economy Package."

2. Whilst the November 2015 Infrastructure Review has yet to be released and the

revised European Circular Economy Package proposal has yet to be finalised,

UKWIN believes that there is still value in providing further evidence in relation to

the Review to support our argument that the facility is not needed and would be

unlikely to divert waste from landfill.

3. As noted in UKWIN's previous submissions, and as supported by the Lock Street

decision, it should not be assumed that proposed feedstock would otherwise be

sent to landfill.

4. The facility proposed for Bilsthorpe intends to treat SRF that could be treated in

other SRF/RDF treatment facilities in Nottinghamshire, elsewhere in the UK or

abroad, and there is no guarantee that the proposed development's limited on-

site sorting capacity will be utilised. There is every possibility that the operator

would be relying on pre-prepared SRF/RDF.

5. As noted elsewhere, there is also the prospect that the operators will struggle to

secure any feedstock for this merchant facility, not least as they are competing

with existing and established companies who benefit from existing long-term

waste management contracts that guarantee the delivery of feedstock, and

because rival facilities would be expected to be capable of processing a wider

range of feedstocks (with a wider range of calorific values, etc.) due to their use

of more conventional incineration technologies.

UKWIN June 2015 Residual Waste Infrastructure Review for Appeal Ref: 3001886 2

Main points from the June 2015 Residual Waste Infra structure Review ('the

June 2015 Review')

6. In UKWIN's primary Interested Party Representation dated 24th February 2015

[IP2] we cited Eunomia's November 2014 Residual Waste Infrastructure Review

and included it as Appendix J.

7. We noted (in IP2) that the Review had been cited in both the February 2013 and

February 2014 versions of Defra's EfW Guide [CD60], and set out the credentials

of Eunomia.

8. In relation to the November 2014 Review we noted that: "Eunomia's November

2014 Residual Waste Infrastructure Review shows that incineration is a

constraint on recycling in England, and that there is no need to consent new

incineration capacity to treat residual waste" [IP2 Para 158] and that Eunomia's

approach "is very conservative and more likely to underestimate overcapacity

than overestimate it " [IP2 Para 160]. The same can also be said of the June

2015 review.

9. According to the June 2015 Review, which UKWIN have provided to the Inquiry

alongside this submission:

• "…[the UK will] move to a situation of potential overcapacity in the UK in

2019/20 (or in 2018/19 if the export of RDF is included in this analysis)…"

• "…it should be noted that 6.5 million tpa of capacity is currently under

construction or committed (i.e. financial close has been reached). The level of

overcapacity then rises to 15.0 million tonnes in 2030/31 (or 18.0 million

tonnes if the export of RDF is included in this analysis)…"

• "…the lead-times involved in the development process, and the level of inertia

in the system associated with this, imply that the pace at which the system

responds to the emergence of over-capacity is unlikely to be rapid.

Furthermore, it should be noted that some new facilities may be expecting to

operate successfully at lower gate fees than some existing facilities. As such,

developers of a given facility may not be discouraged by capacity…"

UKWIN June 2015 Residual Waste Infrastructure Review for Appeal Ref: 3001886 3

• "…As a result of limitations in the ability of waste to be moved significant

distances at low cost, and the fact that capacity is unevenly spread across

the UK, the situation of overcapacity may occur earlier in some geographical

regions than in others."

• "Based on our forecasts of future spare capacity at ‘R1’ facilities in other EU

Member States, we anticipate that export levels of low-grade SRF will

continue to grow over the coming years as the gate fees offer an attractive

alternative to some UK domestic treatment infrastructure."