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SITA incinerator plans
Presentation to Cornwall County Council
17th September 2008
Objections/issues/concerns
1.
2.
3.
4.
5.
Non compliance with the waste
hierarchy
Non-compliance with National Waste
Strategy
Non compliance with PPS 1 Planning and
Climate Change supplement
BPEO and Wastes Local Plan on which
application is based is flawed
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 200965%
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 2015
75% by 2020.
Local targets with incinerator

recycling and composting of household waste:
year

National
Cornwall
2010
40%
31%
2015
45%
47%
2020
50%
47%
recovery of municipal waste:
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

1.
2.
3.
Incinerator vs. Landfill
Uses incorrect figure for carbon
saved from electricity produced
Does not compare carbon on the
same basis for the two options
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
Comparison of GHG emissions for incinerator & landfill
options, calculated on an equal treatment basis
Emission source
tpa CO2e
Incinerator
Landfill
190,474
48,593
72,372
120,544
Net emissions
118,102
13,768
Incinerator worse by
104,334
Emissions
Avoided emissions
Total avoided
However
Sita say
Sita say incin better by
-36,611
49,070
85,700
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
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
0
84
185
198
pa
Savings over
incin to 2020
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