UKWIN’s response to Defra’s Call for Evidence to inform the UK Government’s Review of Waste Policies
The Breathe Clean Air Group are now part of the UKWIN (United Kingdom Without Incineration Network) – www.ukwin.org.uk. UKWIN made several recommendations to DEFRA (4th Oct 2010), as part of a review of waste policies. The full document can be viewed at: http://www.ukwin.org.uk/files/pdf/UKWIN_DEFRA_Submission_4_October_2010.pdf
Several relevant recommendations which you may wish to suggest in your letters of objection to BREP, are listed below:
2.6. Waste volumes are already falling (see section 3 of this evidence) and, given the potential for recycling, the Government should take urgent steps to prevent further provision of waste incineration plants, as these are inconsistent with maximised recycling.
2.7.4. Incineration diverts resources from recycling and diverts biogenic resources from composting and effective energy recovery via AD (anaerobic digestion). The installation of incinerators, which are inherently energy inefficient, produce toxic emissions and massive quantities of CO2 and do not save on GHG emissions, should cease forthwith, and pending the achievement of zero waste, inert non-recyclables should be put to landfill.
2.7.5. Incineration plants devalue the local environment and its communities and do not, for the most part, produce “renewable electricity”. The mixed waste upon which they rely will normally contain a substantial proportion of plastic material. In respect of the biogenic content, there is unlikely to be any assurance that any, or all, of the material will be renewed.
2.7.6. The Government should at least, pending the outcome of the review, impose a moratorium on incinerator planning applications and insist on alternative solutions. Incineration should not qualify for Renewable Obligation Certificates (ROCs) or Packaging Recovery Notes (PRNs).
3.12. UKWIN believes that building new waste incinerators is contrary to working towards a zero waste economy, and should therefore cease. Please see A Bridge Half Built: Zero Waste Declaration included as Appendix A of this submission.
3.20. We need to prevent over-provision of incineration capacity at both regional and national levels for social, economic and environmental reasons. We do not need any new incineration capacity to achieve a zero waste economy. UKWIN believes that building new incinerators would be counter-productive.
3.46.3. Discourage and eventually eliminate the wasteful disposal of recyclables to landfill or incineration;
3.52. UKWIN strongly disagrees with the classification of waste incineration as a form of low carbon energy generation, for the reasons set out above, and because inert waste should never be seen as a renewable or “green†source of energy, and bio- degradable waste should not be seen as feedstock for incinerators.
3.91. Environmentally-friendly processes require less regulation and monitoring than unfriendly ones. Cessation of incineration would reduce the need for regulation and thereby reduce costs.
7.5. Incinerators are associated with the unintended creation of persistent organic pollutants (POPs). In correspondence with the Environment Agency (EA) they have made it clear that planning authorities have a responsibility to honour the UK’s commitment to the Stockholm Convention and the obligations under the 2007 Persistent Organic Pollution Regulations to give priority consideration to alternatives to incineration that do not give rise to persistent organic pollutants (“Annex III substances”).
7.12. Incinerators emit particles including nanoparticles. There is widespread concern amongst scientists over the medical risks that accompany the spread of these particles, both in general and, specifically arising from incineration processes. High temperature combustion processes such as incineration generate nano- particles with metallic, dioxin and aromatic hydrocarbon (PAH) coatings that may be very damaging to health. The review by Cormier et al (Origin and Health Impacts of Emissions of Toxic By- Products and Fine particles from Combustion, 2006) is strong evidence, supported by emerging research establishing tangible public health impacts (Univ. of California study 2008 Air Pollution may Cause Heart Disease; shows nano-sized particles are the most damaging).
7.24. There is increasing evidence that a significant proportion of incinerator bottom ash should now be regulated as hazardous waste in any case; largely due to the high levels of lead and zinc compounds the ashes contain.
9.12. The power output from waste incineration and gasification plants is often described as “renewable”. Much, if not all of it is not. In all cases the percentage of energy in the feedstock that actually emerges as power is small; generally no more than 20% and often less. Partly as a consequence, the CO2 emissions for every unit of power produced are much greater than for a modern fossil power station; so much greater that even if one half of the feedstock does come from renewable sources (and can therefore, arguably, be discounted), the CO2 from the non-renewable element still massively exceeds that from the fossil fuel based power station.