Get ya ROCs off!

On April 30th 2018 Resource Recovery Solutions Derbyshire Ltd (RRS) announced that their controversial waste gasification incineration plant had been granted ROCs - Renewable Obligation Certificates for the electrical energy they will produce from the biodegradable aspect of household waste which the plant will take in for burning.

Renewi one of the parent companies of RRS released a press release relating to the granting of ROCs to the Sinfin Lane, Derby project which contain quite a degree of hot air.

They stated that "Up to 98% of the residual waste managed at the facility will be diverted from landfill, which will also generate enough green electricity to power approximately 14,000 homes."

While the plant may generate enough electricity for 14,000 homes - that is yet to be shown one thing is for sure - an unconfirmed percentage of the power generated will come not from so called green electricity - which is considered by the likes of OFGEM as biodegradable wastes being combusted but in fact non biodegradable waste such as plastics - ie fossil fuels.

It is fact (confirmed via FOI/EIR) that in the city of Derby 9,000 properties have no recycling scheme in place - after Derby City Council removed the service stating recycling bin contamination as an excuse.

What this means is that a percentage of waste entering the Sinfin facility will have had no prior recycling applied to it. Paper and card should have been recycled removing it from the residual waste stream entering the Sinfin site in Derby. Instead such material is condemned to be burnt to generate OFGEM funded electricity via ROC payments - ROCs being funded from green charges applied to our energy bills.

Has recycling been removed in the city to procure suitable waste to generate lucrative ROC payments?

Someone called James Priestley said the following-

James Priestley, Managing Director of Renewi’s Municipal Division, said:

 “We are delighted to have been awarded this important ROCs accreditation which is another significant milestone achieved in this project. Not only does this accreditation bring financial support to the project, it also shows how we are using innovative technologies to operate sustainably, divert waste from landfill and create valuable products from waste. We are looking forward to completing the final stages of commissioning and to providing first class, sustainable waste services for the people of Derby and Derbyshire.”

  Now when you use the terms innovative and first class you think ground breaking and efficient and you could be forgiven for thinking this applied in the Derby projects case but the reality is somewhat different.

At the second public inquiry into the project the planning inspector required RRS to provide evidence of their projects energy efficiency status - an important aspect of the project which was a useful insight into the project.

At the second public inquiry RRS were forced to admit that

 in the plants standard electricity only mode their plant was in fact nothing more than what is known as a D10 disposal plant because the energy efficiency status of the process falls below that which would class the plant as an efficient recovery process.

 

To see what the Waste Framework Directive says about a plant being recovery R1 or disposal D10 below is a series of quotes from the directive.

Recovery or disposal – the meaning of R1

47. The Waste Framework Directive (WFD) sets out the waste hierarchy and enshrines it in law. It requires that a waste management route defined as recovery should be used ahead of an alternative that is classified as disposal. Exceptions can be made (see below) but this general principle makes it important to know whether a process is considered recovery or disposal. 

48. Historically the Waste Framework Directives have included annexes which set out lists of what are considered to be recovery or disposal operations. Each is given a number and a letter: R for recovery, D for disposal. In the current directive the classifications of particular relevance to energy from waste are: • R1 – Use principally as a fuel or other means to generate energy • D10 – Incineration on land 

49. What this means is that where waste is burnt as a fuel to generate energy it can potentially be considered a recovery operation (R1) but where the purpose of incineration is to get rid of waste, it is considered D10 and hence disposal.  All municipal waste incinerators were and are deemed as disposal activities (D10) unless and until they are shown to meet the requirements of R1. This is why the term R1 often crops up in the debate about how good an energy from waste plant might be and how it compares to other options. 

50. For municipal solid waste, which includes all the waste collected from households, the EU has gone further by defining what it considers to be sufficient for recovery status under R1. The WFD includes a formula relating to the efficiency of the combustion plant. A municipal waste combustion plant can only be considered to be a recovery operation under R1 if it generates energy and the plant meets the efficiency thresholds calculated using the R1 formula

SO THAT IS THE OFFICIAL BLURB FROM DEFRA ON RECOVERY OR DISPOSAL PLANTS AS GOVERNED BY EU DIRECTIVES - WHICH STILL GOVERN THE UK SINCE BREXIT.

Why are OFGEM supporting inefficient waste gasification incineration plants? the lure of lucrative subsidies in this case in Sinfin Derby has in part led to the route this project has taken which is condemning resources to being burnt for a small amount of energy made financially viable by government subsidy.

OFGEM are rewarding failure.

©SIMON BACON 2018

Hidden contracts! the public strikes back!

On 22nd October 2015 I Simon Bacon the writer of this blog applied to Derby City Council in Derby UK via FOI / EIR requesting the following information relating to the controversial joint waste contract linked to the highly controversial Sinfin, Derby gasification incineration plant.

 1- ALL CONTRACTS BETWEEN DERBY CITY COUNCIL AND DERBYSHIRE COUNTY COUNCIL RELATING TO THE JOINT WASTE CONTRACT.

 2- ALL CONTRACTS BETWEEN DERBY CITY COUNCIL AND ITS PARTNER DERBYSHIRE COUNTY COUNCIL WITH RESOURCE RECOVERY SOLUTIONS (RRS) AND / OR ITS PARENT COMPANY SHANKS / INTERSERVE.

 3- ALL CONTRACTS RELATING TO THE USE OF THE SINFIN TANNERY SITE - OWNED BY DERBY CITY COUNCIL BY RESOURCE RECOVERY SOLUTIONS (RRS) OR OTHER PARTIES.

 Derby City Council responded on 17th December 2015 in which it disclosed some of the requested information but withheld some of the information in part 2 of the request claiming the adverse affect to the confidentiality of commercial information. What was provided was a series of documents with many redacted (blacked out pages) where the council and its supporters - Derbyshire County Council and Resource Recovery Solutions edited the documents to hide certain aspects of the documents which they did not want the public to see.
Here are a couple of examples from schedule 14 of the contract which covers the performance mechanism.

 

As you can see from the images when they redact information they really black it out!

 

I appealed this ruling and Derby City Council carried out an internal review and responded to me on December 24th 2015 that it maintained this position.

Having considered this battle of wills further I made a complaint against Derby City Council on 22nd February 2016 to the ICO - the Information Commissioner. The ICO then gave full consideration to my strongly put appeal while engaging with Derby City Council further.

The council and its fellow contract members attempted to paint a picture which included impacts on interests of Resource Recovery Solutions (RRS) siting that the withheld information included price mechanisms, volume allocations and proprietary contract tools and processes.

The council argued that RRS operated in a competitive waste market and disclosure would allow competitors to work out the deal and how it was structured resulting in a loss of its competitive edge.

The council went on to argue that the Sinfin waste sites novel nature has the capacity to become a "BEACON OF EXCELLENCE"

 

ENERGOS the developer of the incineration equipment being installed into this beacon of excellence had gone into administration in mid July 2016.
 

It was suggested that the competitors of RRS would benefit from the unique know how contained within the information and thus undermine the ability of RRS to utilise this for its own benefit damaging its commercial interests.

Other than the Derby, Glasgow and Milton Keynes projects that have moved ahead there is little evidence of other projects moving forward using such technology and in recent weeks a proposal to install similar tech on the Isle of Wight has been dropped - so not quite the beacon being suggested.

The ICO asked the council to provide a new schedule setting out in each instance the councils rationale for withholding information so that it matched the specific parts of the documents. Having been given further time to do so the council advised it had approached RRS and Derbyshire County Council but that they had declined to provide any further arguments or clarification.
The ICO in their ruling considered that the lack of clarity in the councils submissions suggests that the council either does not properly understand what the effects of disclosure would be or has struggled to meet the evidential and explanatory burden set by the exception.
 

 On 4th August 2016 the Information commissioner at the ICO RULED IN MY FAVOUR instructing Derby City Council to disclose the withheld information to myself as the complainant.

 

In early September 2016 Derby City Council was in no mood to lose their battle again a resident of Derby so instructed its legal team to appeal the ICO ruling and so work started on a legal appeal.

I as the original applicant was also in no mood to lose the battle and so registered as a party to the appeal which WAS set to be heard later in 2017 in London UK. After a delay of a number of months as two similar cases passed through the tribunal system the Derby case began to move forward.

In recent months a similar case relating to an incineration plant in Gloucestershire and its associated contract pretty much ruled in the original applicants favour - while the council in that case attempted to put a brave face on things while putting some spin on the ruling the applicants in Gloucestershire are very happy with the result of their battle. A similar ruling regarding an incineration plant contract in Worcestershire also placed pressure on Derby City Council who were then set a date by the General Regulatory Chamber who were running the appeal by Derby City Council where the council had to acknowledge if it proposed to continue with their appeal.

So two other appeals went against the local councils which forced Derby City Council into a corner over their appeal against the ICO ruling.

 Did they continue or did they rollover!

 

THEY ROLLED OVER AND BAILED OUT OF THEIR APPEAL ON MAY 11TH 2017

The councils legal team made the following statements when terminating the councils appeal.
"

"Our clients have been carrying out a fresh, detailed, careful and considered review of the disputed information with all interested parties taking into account the passage of time and developments since the initial request and the commencement of the Appeal.

Having concluded that reassessment and made recommendations accordingly, the interested parties have respectively reached agreed conclusions and advised the relevant public authority which has been able to make an updated decision on disclosure as a result.
Our clients have invested a great deal of time in reaching this decision and it is not one that has been taken lightly. Despite considering that much of the disputed information remains commercially sensitive and confidential, given the time that has now passed since the original request for information by the applicant and taking into consideration the current stage the facilities are now at, the likelihood of probable harm from disclosure of the disputed information into the public domain has reduced.
As a result our clients have asked us to confirm that the disputed information will be disclosed in its entirety. "
 

 Derby City Council admitted at a recent full council meeting that they and their supporters - Derbyshire County Council and RRS / SHANKS had already spent £20,000 on their fight to keep aspects of the Derby and Derbyshire waste contract secret - hidden away from the public. In a strange twist they appeared to be suggesting to the local newspaper the Derby Telegraph that they had NOT paid £20,000 to stop me from gaining a copy of the contracts as reported here http://www.derbytelegraph.co.uk/derby-man-wins-right-to-see-controversial-sinfin-incinerator-contract-but-council-to-appeal/story-30288364-detail/story.html

 

The council was simply playing with words - £20,000 was spent but the city council only paid a third of the payment!

What are they trying to hide from the residents of Derby and Derbyshire ? what is so controversial that they redact whole pages of their waste contract ?  In these times of austerity and government cuts surely the public have a right to know what their taxes are being spent on.

NOW WE HAVE THE CHANCE TO FIND OUT!

©SIMON BACON 2017

 

Dont put it in the recovery position !

It was a simple innocent question that I put to Resource Recovery Solutions at a meeting of the Sinfin waste incineration plants Community Liaison Group (CLG) meeting back in early 2016.

 

We were part way though a presentation by a representative of RRS / SHANKS in relation to what they teach school children they visit at schools across Derby and Derbyshire or tours the construction site with and I was feeling somewhat uneasy that the councils were paying a company that was being employed to burn vast volumes of waste to then also educate school children what we should do with waste.

So at that point I thought hey ho lets just pop a question across to the the RRS / SHANKS  just to satisfy myself that they were in fact educating school children correctly and that I was being unfair to judge them. It was at this point that a representative of RRS / SHANKS (named in the meetings official minutes) told the meeting that they told children it was a recovery plant.

WOW THERE ! WOW THERE ! now hold on just a minute ! did they say it was a RECOVERY PLANT ? really ! a RECOVERY PLANT ?

 

Now burning waste is a funny old game because doing so can be considered to be one of two things when it comes to considering the process in the waste hierarchy it is considered a disposal process unless it can prove otherwise in which case it is a recovery process.

 The waste hierarchy just for clarity is a set of processes when dealing with the whole issue of waste that must be considered as it takes in best practices to deal with waste in the most sustainable way.

It starts with REDUCTION / PREVENTION where the aim is to reduce what waste we produce so managing materials in the best way - by not using them to start with ! Then we have RE-USE which is where whenever possible we take items that are now scrap and attempt to use them again in an innovative way to keep them out of landfill and incineration. Then comes RECYCLE which is when materials at the end of their life if not reused are reprocessed into new items by making use of the products raw material make up. As we head down the hierarchy we get closer to less sustainable methods of waste management such as incineration and landfill - neither of which are good methods of waste disposal. This brings us to RECOVERY which is when those handling waste start to use wastes for energy generation such as in incineration plants which meet an efficiency target called R1. These are plants which can show that their efficiency of energy generation meets a strict target and often requires such plants to export large volumes of heat or steam to customers to meet that efficiency rating. Finally we come to DISPOSAL which includes inefficient energy generation in incineration plants and also landfill.
In a twist to things a plant that meets R1 efficiency targets is STILL a disposal plant until it is granted recovery status.

Now rather conveniently for the UK government they use a waste hierarchy image as shown below which I consider to be incorrect as it blurs the lines between recovery and disposal in the waste hierarchy by using questionable wording.

The image shown below is the image in question and is used by DEFRA in their document

Energy from Waste a Guide to the Debate dated Feb 2014
 

 

Now reviewing the image it would be very easy to be misled into thinking that any incineration plant - including gasification is recovery in the waste hierarchy if it generates energy. The image appears to imply this is the case and as this image is commonly reproduced a gross misunderstanding takes place!

It is only when you take the chance to read other areas of the document that the issue of R1 and its application are considered and at that point you realise the difference between recovery and disposal. Obviously there are some who favour this blurring as it allows them to paint a picture of a project that makes it conveniently sound better than it is.

To aid you readers below is produced a series of statements from DEFRA from the document in relation to R1 and what is known as D10 disposal.

 

Recovery or disposal – the meaning of R1

47. As described above the Waste Framework Directive (WFD) sets out the waste hierarchy and enshrines it in law. It requires that a waste management route defined as recovery should be used ahead of an alternative that is classified as disposal. Exceptions can be made (see below) but this general principle makes it important to know whether a process is considered recovery or disposal. 

48. Historically the Waste Framework Directives have included annexes which set out lists of what are considered to be recovery or disposal operations. Each is given a number and a letter: R for recovery, D for disposal. In the current directive the classifications of particular relevance to energy from waste are: • R1 – Use principally as a fuel or other means to generate energy • D10 – Incineration on land 

49. What this means is that where waste is burnt as a fuel to generate energy it can potentially be considered a recovery operation (R1) but where the purpose of incineration is to get rid of waste, it is considered D10 and hence disposal.  All municipal waste incinerators were and are deemed as disposal activities (D10) unless and until they are shown to meet the requirements of R1. This is why the term R1 often crops up in the debate about how good an energy from waste plant might be and how it compares to other options. 

50. For municipal solid waste, which includes all the waste collected from households, the EU has gone further by defining what it considers to be sufficient for recovery status under R1. The WFD includes a formula relating to the efficiency of the combustion plant. A municipal waste combustion plant can only be considered to be a recovery operation under R1 if it generates energy and the plant meets the efficiency thresholds calculated using the R1 formula

SO THAT IS THE OFFICIAL BLURB FROM DEFRA ON RECOVERY OR DISPOSAL PLANTS AS GOVERNED BY EU DIRECTIVES - WHICH STILL GOVERN THE UK SINCE BREXIT.

So returning to what the RRS / SHANKS representative said they teach students the plant is. they stated they teach students that the plant is a RECOVERY plant - which raises the issue of R1 as noted above.
When we consider R1 and the claims of the RRS / SHANKS representative we know what they are teaching children is false because at the 2nd planning inquiry the developer had to admit that their plant fails the R1 test in its standard mode.
If you tell children something that is false then in general it is usually considered a lie.
It is a lie in this case because staff employed in waste disposal and waste management will know the requirements of the waste hierarchy

 IT IS THEIR JOB.


©SIMON BACON 2016

Derby City Council - The public are being robbed! Derby and its unfair share!

With just over a year to go until the Resource Recovery Solutions (RRS) waste gasification incineration plant is completed on the ex tannery site on Sinfin Lane, Sinfin, Derby we find that Derby City Council's thoughts are turning to the payment they will be due to make to their contractor Shanks as their share of the build costs from the joint waste contract with Derbyshire County Council. Due to enter service on April 1st 2017 - no seriously April Fools day the plants construction is well under way with the recent construction of the plants 55 metre high smoke stack that now dominates the local community - even glowing a sinister shade of red at night.

The stack is to the left end of the storage container

The new stack looms over the local bowling alley at night

 

A Derby City Council document submitted for the 20th January 2016 cabinet meeting shows that the council are already lining up their payment of £25 MILLION

 

So that's £25 million to be paid in just over a years time when the plant starts accepting contract waste - the total payment by the councils being £50 million paid as an equal share by both councils.

We know its being paid as an equal share because the waste contract tells us this - in the image below.

Now when paying an equal share in a relationship such as this you would expect the councils to be equal partners. Derby City Council - and so its residents already have to host the controversial waste incineration plant while the county faces none of the controversial issues such a plant brings.

SO IS THIS AN EQUAL PARTNERSHIP?

IT WOULD APPEAR NOT!

The Inter Authority Agreement between the councils sets out issues around what they call the NWTF which is the New Waste Treatment Facility - which is being built on Sinfin Lane. Most of us call it what it is - an incineration plant.

An equal partnership would be a 50/50 split in everything - from the payments the councils are to make through to the plants projected use.

While the councils are indeed paying equal shares do they get equal benefit?

 

Paying 50% of the council payment towards the build cost of the plant - £25 million should allow Derby City Council to send 50% of the waste to the 190,000 tonne a year plant.

BUT!

Derby City Council DOES NOT collect 95,000 tonnes of residual waste! 

DEFRA waste findings published in December 2015 for the year 2014/15 highlight that the city council collected 114,800 tonnes of waste BUT after recycling is taken into account it only collected 79,320 tonnes of residual waste! leaving the council over 15,600 tonnes short!

 

So why are Derby City Council and its residents getting the raw deal here!

PAY 50% OF THE BUILD CHARGE WITHOUT THE SAME BENEFITS OF YOUR PARTNER!

Once again the residents of Derby are being short changed - and at the agreement of their council! 

 

©SIMON BACON 2016

 

 

 

 

 

Burn baby burn !

One of the biggest myths in waste management is that the new Advanced Thermal Treatment (ATT) plants are not incineration plants! Time and again when these new plants are wheeled out by councils and developers we are told they are clean, green AND NOT INCINERATION !
Developers put forward exotic names for the processes they are trying to peddle like GASIFICATION or PYROLYSIS and they claim their processes do not burn wastes but heat them producing syngas which is then used for power generation.
While standard mass burn incineration burns waste in an oxygen rich environment developers peddling their alternatives often use controlled levels of air / oxygen and in some cases no oxygen in what they consider to be a more controlled process. These processes are now being pushed across the UK and in recent years a number of proposals have been put forward for Derby and Derbyshire.
Councils and developers when attempting to gain planning permission favour using terms such as gasification and pyrolysis because by doing so it keeps the word incineration out of the public eye because when rumbled councils and developers come up against stiff opposition.
Such processes are claimed to be clean and green and at times even those who object to waste incineration plants are fooling into thinking such plants are a better alternative to mass burn incineration and this extends to government who now offer subsidies for electricity produced by Advanced Thermal Treatment plants. The elephant in the room is that mass burn, gasification and pyrolysis are ALL incineration plants because no matter if its a throw it in and burn it plant or a plant that produces syngas via controlled processes when the gas is burnt its an incineration plant.
We know this because Europe have defined what constitutes an incineration plant in the waste incineration directive - often known as WID.  This set of regulations sets out the description of such plants, their control and the expected emissions standard for the plant.

 

So while up and down the country the same argument can be heard at waste gasification plant public consultations about the proposals not being incineration councils and developers cannot escape facts ! and the facts are EUROPE SAYS THESE PLANTS ARE INCINERATION PLANTS! So that is what they are!

 







©SIMON BACON 2016