SEPA Guidelines for Thermal Treatment of Municipal Waste Analysis

SEPA Guidelines for Thermal Treatment of Municipal Waste Analysis of responses to Consultation Final Report March 2004 BGE0011916 Babtie Group 95 Bothwell Street, Glasgow G2 7HX Tel 0141 204 2511 Fax 0141 226 3109 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste Contents 1.0 2.0 3.0 4.0 5.0 6.0 Introduction Background Methodology Analysis Key Issues of Concern Conclusions 1 1 2 3 6 7 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste 1.0 Introduction This document has been prepared by Babtie Group on behalf of SEPA and presents an analysis of the responses received from consultation on SEPA’s Guidelines for Thermal Treatment of Municipal Waste issued by SEPA in December 2003. 2.0 Background The current practice of landfilling 90% of Scotland's municipal waste is unsustainable and must change. The National Waste Strategy: Scotland sets out a framework to change the way we deal with our waste in order to move to a more sustainable position. During 2002 SEPA consulted on its guidelines for thermal treatment plants. The purpose of the consultation was to set out SEPA’s views on the role of energy from waste technologies in the context of the National Waste Strategy: Scotland and to encourage wider public debate about the role of these technologies. SEPA received 129 responses to the 2002 consultation. Considerable work has taken place since then in light of all the comments received and further legal advice, although the fundamentals of the guidelines have not changed. As a result of these changes since the first consultation period it was considered appropriate to allow the 129 people who responded previously to make further comments. The further consultation period was from 18 December 2003 to 16 January 2004. From the 129 people asked for further comment 40 responses were received. This document is an analysis of those further 40 responses. 1 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste 3.0 Methodology The second consultation was made in the form of a general enquiry, giving consultees the opportunity to comment on the SEPA Guidelines for Thermal Treatment of Municipal Waste. The analysis considers responses from the consultation by drawing together similar responses, and by considering the responses by category of consultee and by their geographic location (Local Authority areas). The categories of consultee were: • • • Members of the public Private Companies Others The comments from consultees were also compared where possible to those received from that consultee in the first consultation. The procedure used in the analysis consisted of four stages: Stage 1: The responses were reviewed and grouped into categories according to the type of consultee. Stage 2: In order to break down the responses into their geographic location the postcodes were identified and allocated to appropriate Local Authority areas. (It should be noted that for five of the responses sent by e-mail no postcode could be identified.) Stage 3: A short summary of each of the responses was produced in tabular form with similar comments grouped together under each of the categories of consultee and a comparison was made of the consultees’ comments received previously. Stage 4: The sorted data was reviewed in order to draw out and present the key issues of concern. The result of the analysis is described in the text of this report under sections 4.0 and 5.0. Conclusions on the data are presented in section 6.0. 2 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste 4.0 4.1 Analysis This section presents a summary of the analysis in the form of tables. It should be noted that these are the views expressed by the consultees and do not necessarily reflect the opinion of SEPA. A total of 40 responses to the consultation were received. Responses from members of the public were in the majority at a total of 37. Private companies returned 2 responses. Scottish Natural Heritage sent a letter saying that as their previous comments had been accommodated that it had no further comments. A breakdown of responses by source is given in Table 1. Table 1 Responses by Source Source Members of the Public Private companies Others (SNH) Total Number of responses 37 2 1 40 4.2 4.3 Division of the responses into Local Authority Areas shows that the majority of the respondents were from the City of Edinburgh (10) and Aberdeenshire (6). Three respondents were from Dumfries and Galloway. Table 2 shows a breakdown of the different categories by their geographic location. Table 2 Responses by Geographic Location Local Authorities City of Edinburgh Aberdeenshire Dumfries & Galloway Falkirk Fife Moray Dundee City Perth & Kinross North Lanarkshire East Lothian North Ayrshire Glasgow City Angus Western Isles Council Perth & Kinross Area wide Public Private SNH 10 6 3 2 2 2 1 1 1 1 1 1 1 1 1 1 4.4 Most consultees provided comments on the practical implications of the Guidelines, supporting statement 5 and supporting statement 6. With respect to these key concerns it should be noted that: 3 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste • • • 4.5 88% stated that there should be no exceptions regarding the practical implications of the Guidelines 85% stated that incineration of municipal waste without energy recovery should be absolutely prohibited rather than treated as a last resort 93% stated that there should be no circumstances in which it would be appropriate to burn unsegregated municipal waste One of the public consultees made the following comment with regard to Supporting Statement 10: • The potential environmental harm of transporting waste between areas should be taken into account in assessing these plans and that once a large plant is established, the economics and investment in it may act as a disincentive for waste-reduction and improvements at the top of the waste hierarchy 4.6 The comments of a private company are summarised in Table 3. Table 3 Comments from a private company Title The title is misleading: What are the guidelines for waste which is not classified as municipal solid waste. It is unclear what SEPA's view is on the Waste Incineration Directive The policy Guidelines should encourage the Best Practical Environmental Option (BPEO) principle where it is obviously preferable to incinerate MSW rather than bury it in landfill sites. Incineration has the benefits of vastly reducing the residual volume and also producing some energy in the process. The guidelines seem to be directed to limit or punish incineration schemes. The public have some misplaced perception that all incinerators produce noxious fumes and dioxins. The fact is that modern plant is very efficient at removing noxious emissions as required by the PPC regulations. Does not seem to provide for Anaerobic digestion which is mentioned in supporting statement 6 If the National Waste Plan concludes that thermal treatment is an appropriate option it is incumbent on SEPA to support rather than not oppose to concept. Developers will require that SEPA is accountable for its original endorsement and assists to overcome misinformed public opposition which invariable surfaces as soon as a chimney appears. The alternative will be to landfill vast amounts of municipal waste, which has the potential for landfill gas and escaped leachate. The incineration process properly designed is more controllable and complete than landfill, which will have residual effects for many years to come. The public need to be educated as to what is good for them before the landfill morass becomes out of hand. SEPA must take into account the disposal and recycling of residues when determining a PPC permit. Surely it would be fairer if the outcome and residue was compared with any alternative means of disposal to determine which was worse. The policy guidelines Table 1 Guideline 1 Supporting Statement 2 Supporting Statement 3 4 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste Guideline 2 Supporting Statement 5 Supporting Statement 7 Guideline 3 Guideline 4 Supporting Statement 10 Table 1 seems to allow for disposal including burning the waste without energy recovery. Supporting statement 5 seems to almost rule out this possibility. How is disposal of Medical Waste and the Directive handled? How is the Best Available Technique (BAT) fairly determined when there may be several similar processes available on market? Each system will probably have some form of weakness. A limitation of substances to be processed does not allow any flexibility over the non-consistent composition of municipal waste. Municipal waste is liable to change over the years as the public's habitual behaviour alters. It is essential that money is invested in R&D so that new technology is encouraged to enter the market. It makes sense that large centralised plants provide efficiencies of scale which will outweigh the environmental effects of transport from outlying areas. 4.7 In addition to comments to the consultation document, a number of consultees supplied additional information and discussion on general issues associated with energy from waste technology and its place in waste management. This information is including the following statements. • If waste has to be burnt, then its heat should be recovered for pre-heating, electrical power, space heating, greenhouses or any other process requiring heat (1 response). • Only large, centralised incinerators could support the extra plant for heat recovery and the plume from its stack might therefore carry a dangerously high level of pollution. The answer is to develop wider ranges of recyclable material (1 response). • On the general issue of waste, it seems that SEPA has the obligation to raise its voice against overpackaged goods and the use of non-recyclable material (1 response). • In the case of island communities, the installation required to facilitate an energy recovery system may have a detrimental impact on the natural and archaeological status of the island. Options are either proceeding with the existing incinerator, or revert to all waste being shipped off the island for disposal (1 response). 4.8 When comparing the responses of the first consultation with those of the second consultation, there is no change in opinions noticeable (except that already noted for Scottish Natural Heritage). The responses are relatively consistent throughout. It was noted during the analysis that a large number of the responses from members of the public (35 out of 37) were almost identical suggesting an organised response. 4.9 5 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste 5.0 5.1 Key Issues of Concern This chapter summarises the key issues of concern expressed by the consultees. There should be no exceptions regarding the practical implications of the Guidelines Incineration of municipal waste without energy recovery should be absolutely prohibited rather than treated as a last resort. There should be no circumstances in which it would be appropriate to burn unsegregated municipal waste. The potential environmental harm of transporting waste between areas should be taken into account in assessing these plans and that once a large plant is established, the economics and investment in it may act as a disincentive for waste-reduction and improvements at the top of the waste hierarchy. The policy Guidelines should encourage the BPEO principle where it is obviously preferable to incinerate MSW rather than bury it in landfill sites. However, the guidelines seem to be directed to limit or punish incineration schemes. If the National Waste Plan concludes that thermal treatment is an appropriate option it is incumbent on SEPA to support rather than not oppose to concept. Limitation of substances to be processed does not allow any flexibility over the non-consistent composition of municipal waste. In the case of island communities, the installation required to facilitate an energy recovery system may have a detrimental impact on the natural and archaeological status of the island. 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 6 Prepared for and on behalf of SEPA By Babtie Group SEPA Consultation: Final Report SEPA Guidelines for Thermal Treatment of Municipal Waste 6.0 6.1 Conclusions The largest number of responses were from members of the public, who mainly made comments on the practical implications of the Guidelines, Supporting Statement 5 and Supporting Statement 6. Of those, some 96% were almost identical in their answers. They may therefore represent the outcome of an organised response with the result that including them in the analysis at face value may distort the conclusions of the analysis. As indicated in the conclusions given in the first consultation report, grouping together of identical public responses would be more statistically representative. The comparison of responses of the first consultation with those of the second one shows that there are no significant changes in the consultees’ opinions. 6.2 6.3 7