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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."